![](media/image1.png){width="1.1041666666666667in"
height="1.1041666666666667in"}**EPA's Radionuclides Rule Web Cast**

**Written Transcript**

August 4, 2004

**Margaret:** Welcome, ladies and gentlemen, to today's Radionuclides
Rule Seminar hosted by the EPA's Office of Groundwater and Drinking
Water (OGWDW). Before we begin today's seminar, I would like to review a
few housekeeping items. First of all, if you haven't clicked on the
"Join Now" button located in the upper right hand corner of the page,
please do so now. This will launch today's Web cast. If you need
assistance with the audio or web portion of today's event, please
contact Customer Care by pressing \*0 on your telephone keypad. You may
also dial 1-800-290-5900.

We would like to acquaint you with some of the ways you can participate.
As you look at your screen, you will notice a small text box in the
lower right hand side labeled "Ask a Question." You may ask a question
throughout the presentation by clicking on the "Ask Question" button,
typing your question and clicking "Ask." Your question will be addressed
during today's presentation. Also, by pressing Control H on your
keyboard, this will allow you to expand the image to full screen;
Control H will also bring you back to the Live Meeting console features.
Again, should you need help at any time during this seminar, press \*0
for an operator. I'd like to introduce Andrea Matzke from the EPA's
Office of Groundwater and Drinking Water Protection Branch, now. Andrea,
take it away.

**Andrea:** OK. Thanks, Margaret. I'm Andrea Matzke and I work in the
Office of Groundwater and Drinking Water here at EPA's Drinking Water
Protection Program and I work in Radionuclides and Arsenic
Implementation. So, I'd like to welcome everyone to the second
radionuclide Web cast that we've had and today we're going to be
focusing on radionuclide treatment technologies as well as disposal of
residuals. And I know a lot of you are interested in this topic and just
while I'm bringing this up, we have a radionuclides residuals document
that we have been working on in the past few months or so and we did
sent it out for review today and we're expecting comments by the end of
this month. And so once we get those comments back, we can make some
revisions and, hopefully, get this out by fall to everyone.

We do have a lot to pack in today, actually, we only have a couple of
hours for this topic, so what we're going to do is we're saving most of
the questions until the very end. We'll have 15 minutes at the end for
questions and answers and we'll also address one question after each
presentation. Each presenter will be able to take one question with some
of those questions coming from email, as you did last time, and some of
the questions coming from questions that were sent into us ahead of
time. We really appreciate those folks who were able to send questions
into us ahead of time. So, with that, we're actually going to skip a
speaker and go straight on to Rajiv Khera and he will be talking about
the SPARRC model. Rajiv works in the Office of Groundwater and Drinking
Water with myself. So, Rajiv, if you are ready?

**Rajiv**: Thank you, Andrea, I'm ready. Hi, everyone. My name is Rajiv
Khera. The topic of my presentation is SPARRC, which actually stands for
Software Program to Ascertain Radionuclide Residual Concentration. For
this model, I'd like to acknowledge SAIC for its support. Next, Suzanne.

I'll cover the following topics during my presentation today. First of
all, I'll provide a brief background on this model, state the model's
objective, and lay out a case for its usefulness. Then, I'll present the
overall design approach and the main features of the tool. Next, I'll
briefly discuss the technologies covered in the model and will summarize
SPARRC features. Finally, I'll do a brief demonstration of the tools
softening module. Just as a reminder, I have only ten minutes for this
presentation, so if you have any questions, please email them to me or
to Andrea and I'll respond to them ASAP. Next.

So, what is SPARRC. It's a mass balance model designed to predict
estimates of concentration of uranium and radium in treated water. Now,
its level of precision is for pre-design decision making that systems
can evaluate various treatment technologies from the waste perspective.
These key features in the model were prompted by the recommendations of
a 1992 Science Advisory Board Panel. So, then next.

The current version, which is about to be sent for external peer review,
is a stand-alone application program using Visual Basic that models
radionuclide mass balances for six treatment technologies. Now this
application, this software can be used on any computer as long as you
have a Window Operating System with Windows 2000 or higher version. The
treatment technologies modeled in this model are conventional filtration
for uranium removal, lime softening for both radium and uranium, and ion
exchange for uranium and ion exchange for radium. There is reverse
osmosis for uranium and radium and activated alumina for uranium and,
finally, filtration for radium. Next slide, Suzanne.

So, what are its capabilities? SPARRC is designed as a predictive and
decision making tool for utility operators and for regional and state
regulators. In particular, SPARRC can provide information to make
comparisons among technologies by raising quantity and contaminant
concentrations, and radionuclides removal efficiency. This capability
will also help identify the most effective way to treat source water and
address waste disposal needs. Now because of SPARRC, the user can
manipulate a variety of operating parameters. Another capability of the
model is providing information for treatment optimization and waste
treatment and disposal planning. Next slide.

For our next steps on this project, we are initiating an external peer
review of the model. Also, I would like to take this opportunity to
request that you review this model and of course we will always welcome
your comments as well as the field data which will help us improve the
precision and accuracy of the model. Now the model is available at this
website: npdspermits.com/sparrc and for your convenience you can submit
the field data and your comments on the same website. Next, I am ready
for the demonstration.

Now I would like to demonstrate SPARRC. But before I get started I would
like you to please press control key and please press H key for a full
screen display of the model. For the first time users you may want to
start from the middle window and this window will take you through a
step by step description, it will give you step by step description of
the model. Now at the top you can see individual modules for six
treatment technologies that are modeled in SPARRC. In the interest of
time I will focus only on the demonstration of the lime softening
module.

Now the input variables as you see them on the screen are on the left
side of the screen, the 1/3 of the screen on the left inside. To input
numbers you need to either click or type. To display the description for
each input variable just put the mouse arrow over the input variable and
it will change the color, change the color to red and a guidance
document statement will pop up which contains the boundary conditions
associated with this variable and the information on its units.

The output which has a sort of gray blue background is on the rest 2/3
of the screen. The top portion shows chemical dose requirements, and
treated water concentrations of uranium, radium, and hard methylclenatie
in the treated water. In the lower portion, the model predicts
concentration of radium and uranium in individualized screens, such as
backwash and sludge, as well as in the total waste screen when these
waste screens are combined. At the very bottom of the screen there are
buttons to help user understand the lime softening process and modeling
steps and the method by which they can deliver a port and set up their
printer.

Now the input variables going back on the input side, the input
variables which are preceded with a red dot, so then if you want to go
on alkalinity for example, indicate to the corresponding input variable
like in this case alkalinity or pH is an important determinant to the
model output. When you click on it, the corresponding information links
to other relevant information which is displayed. Now going back to the
input section, the SPARRC catches the variables in the lime softening
process and accounts for all water parameters such as pH, alkalinity,
carbonate hardness, magnesium hardness; it also accounts for process
variables such as design and average flow, treated water carbonate,
desired treated water carbonate and magnesium hardness; and variables
related to chemicals such as type of lime, quake or slate lime, polymer
dose; and finally it also captures backwash process variables, such as
backwash loading (?), backwash time and backwash interval.

Now on the output side some of the output variables are preceded with a
yellow dot. Clicking on the yellow dot links you to information
outlining how SPARRC estimates the contaminate removals and provides
references for the methodology, the logic used in this model. Now some
output variables are preceded with a green dot, for example on backwash,
so then you may want to go on the backwash if you click on that, this
will show the key math balances equation for the selected topic.

So now the next question is how SPARRC mimics lime softening. Now
without going into the details of lime softening process, basically,
based on alkalinity and pH the software calculates the CO2 level, you
may want to move on the right so then on the treated water side at the
bottom, yes, it calculates the CO2 level and from there the amount of
lime needed to precipitate calcium hardness. So, which you can see under
the PO lime dose. So then where you have the required chemical dose, it
also calculates lime and soda ash doses needed to precipitate magnesium
hardness. Now the basic premise is that in reality treatment plants do
not soften the water to the point of solubility limit and generally
would prefer to either bypass some of the flow of use a lime dose that
will precipitate hardness to a level that can be ever as high as 130ppm.
Now it captures the complex relationship between pH, lime dose, soda ash
dose, and magnesium present to estimate the amount of radium and uranium
removed. This is based on our standard Caldwell-Lawrence diagrams, rest
assured we have not invented it.

So, as a quick demonstration, so then if you show a situation when the
alkalinity is less than the total hardness, which is the case here and
you have non- carbonate hardness here represented as magnesium hardness
greater than 20 mg. So if you increase that to 20.1 you see that the
model triggers a need for soda ash and excess lime. Now in the case when
the alkalinity is equal to total hardness, it only triggers need for
excess lime and similarly for uranium removal it is well established
that the optimum level of magnesium hardness is desired for its
effective removal and this model captures it. For example, Suzanne if
you increase the, if you show the uranium removal now on the right hand
side, show the uranium removal on the right hand side in the treated
water, now go back and increase the magnesium hardness, now you can see
the uranium removal under this scenario co-precipitates with the
magnesium hydroxide. So at pH's greater than 10.8 in the treated water
and magnesium carbonate greater than 20 mg per liter uranium removal is
expected to be over 90%.

Now, I'm done with the demonstration and I just want to raise a question
here and I'm sure that the question that you might have is how accurate
are the model predictions. I believe we have done a good job in mass
balancing the relationship between the variables. This model is based on
sound science and empirical data which we have referenced in the model.
Also we have captured the important relationship between the most
relevant raw water and operation variables and the final output, such as
how alkalinity and pH affects our radium removal or how magnesium level
in the raw water influences the uranium removal. However like with any
of the models, this model also requires field data for validation and
calibration and that is where we need your assistance. We believe if we
have the field data then the model predictions should be within plus
negative 10% of actual value. I'm done. So if you have any questions,
please email them to us. Thank you.

**Andrea:** Thanks Rajiv, I think we might have time for one question, I
don't know if we had a question that came in, I'm looking
through....let's see, OK it looks like we have one, not sure if I can
read the whole thing here. "Have you validated this model with a pilot
study?"

**Rajiv:** No we have not and that's why we are requesting field data.
We have not piloted any to validate this model. But we did run some
field data and we had AWWA review this model extensively for us and we
got very favorable comments. And based on some of the data that we had
our predictions, the model predictions are pretty close to the actual
numbers. But we definitely need more data; we definitely need more field
data.

**Andrea:** Great, thanks Rajiv. If anyone else has any other questions,
again we'll be posting the questions and answers from this Web cast on
our website after the Web cast. There was another question that came up,
"where are the question and answers are from the last Web cast?" It's a
good question and we're still working on those questions. They had some
very complex questions that were out there and so we are still working
on those and they should be up on our website by next week. So I guess
we'll go ahead and go onto our next speaker who is Kevin Keenan, and
Kevin worked for the Montana Department of Environmental Quality for 26
years and is now working with the Cadmus Group for the past 5 years.
He's been doing a lot of training for a number of our drinking water
rules and he'll be talking about some of the disposal options for
residuals, so Kevin if you're ready?

**Kevin:** I'm ready, thanks Andrea. We have a presentation here that's
about 36 slides long and about 33 or 34 minutes to do them so we'll move
through them rather quickly. This issue does not lack for complexity.
It's important that water system owners and operators understand that
there is a possibility and it's a real possibility that has to be
watched for, that when they remove contaminants from their waste water,
those contaminants may accumulate to produce a waste which is more
difficult to dispose of than it might have been because of the presence
of radio-nuclides of other contaminants.

This first slide of course, the title slide we just want to call your
attention to the fact that treatment processes, if they are
appropriately designed and operated, are going to be operating to meet
drinking water standards expressed as an MCL. The bottom line here is
that if the treatment processes will in fact concentrate contaminants
into solid or liquid waste streams that require appropriate handling and
disposal, that's what we're here to talk about today.

The options for disposal are going to be influenced by a variety of
things and we've listed a few on this slide. Number 1 is the
concentration of radionuclides and co-occurring contaminants in the
wastewater stream. You have to think about hazardous waste, that is the
definition, the defined term hazardous waste. Under federal and state
laws you have to think about TENORM, the technologically enhanced
naturally occurring radioactive materials that might accumulate in
higher concentrations. Low-level radioactive waste, the concept of mixed
waste that is radioactive waste and a hazardous waste mixed together.
Need always be mindful of federal, state, and local regulations and I
think for emphasis, it's important to highlight state and local
regulations, because they seem to be those regulations that will be the
biggest players in this kind of decision making. And then of course
there's a need to be concerned with the type of residual that you're
dealing with or that you may deal with, depending on the kind of
treatment that you propose to use or that you are using.

Definition for waste, of course there is a definition in the law for
hazardous waste, remember this is a defined term. TENORM,
technologically enhanced naturally occurring radioactive material, this
also is a term of art, although it's not precisely defined. Low-level
radioactive waste and mixed waste we'll talk about very quickly in this
presentation. Remember that hazardous waste is regulated under RCRA, the
Resource Conservation and Recovery Act. The definition of solid waste is
first determined for the purposes of the definition in the law and it
includes sludge from water supply treatment plants among other things.
And then a solid waste is a hazardous waste if its not excluded from
regulation under this section that we are showing right there in the
slide or if it exhibits a characteristic of toxicity, corrosivity,
reactivity, or ignitability listed also in the citation that's shown.
Remember hazardous waste can also be specifically listed. It's important
to keep in mind that the presence of radionuclides, in and of itself, in
and of themselves does not make the waste hazardous.

The concept of TENORM. This is a very broad subject but, it is regulated
not specifically as TENORM, but regulated by numerous federal
regulations. Remember it's defined as naturally occurring materials that
are concentrated during some process and that represent a potential for
harm to humans because of exposure to those concentrated amounts. It
does include a variety of waste streams generated by water treatment
plants, it also is often found in fertilizer plants, mining, and oil and
gas production. There is a great variety and if you're interested in a
little bit more on TENORM, the concept of TENORM, there is a website
that the EPA maintains
([www.epa.gov/radiation/tenorm/faq.htm](http://www.epa.gov/radiation/tenorm/faq.htm))
where there are some questions and answers.

Low-level radioactive waste is defined by the low-level radioactive
waste policy act and it's kind of defined in a backwards, in a backdoor
way, in other words defined in part by what its not. Low-level waste is
not a high level radioactive waste, but nuclear fuel byproduct material
and then it is classified by the Nuclear Regulatory Commission as a
low-level radioactive waste. It's important to know that if source or
special nuclear materials are in a waste it may be a low-level nuclear
waste. Radium is not a source or byproduct material, by definition, but
uranium and thorium are source materials and may be subject to Nuclear
Regulatory Commission licensing requirements.

If uranium or thorium (that may be source materials), make up less than
0.05% or 1/20^th^ of 1% by weight, and the total is less than 15 pounds,
then this is going to be a source material that is of unimportant
quantity and will then be exempt from NRC regulations. That can be
translated in terms of picocuries to, for natural uranium to 335
picocuries per gram. That definition that you see on the slide right now
actually comes out of two different sections in the law. The first is
the issue of an unimportant quantity and the second is a small generator
which is less than 15 pounds. If uranium or thorium make up less than
0.05% and the weight is less than 15 pounds, then it won't be necessary
for a person to get a license from NRC for the presence, disposal, or
transfer of that material.

The issue of mixed waste is one that's come up many, many times over the
past several years when we've talked about the upcoming arsenic
regulations and the upcoming radionuclide regulations. The issue here is
that if a waste contains both a hazardous waste, now that's under the
definition in RCRA, and a source or byproduct material subject to the
Atomic Energy Act, then it may be a mixed waste. But keep in mind that
we just talked about an opportunity for exemption and an opportunity to
be determined to be an unimportant quantity. More than 0.05%, more than
1/20^th^ of 1% uranium or thorium by weight and totaling more than 15
pounds plus hazardous waste may make a mixed waste subject to a general
license from NRC or Agreement state. Now the key here is that you have
to have both. If you have the uranium or thorium in the quantities but
you do not have a defined hazardous waste you're not going to have a
mixed waste and vice versa. So it's important to remember that before
you trigger the definition of a mixed waste, you must have both, and if
either one is not there then you don't have a mixed waste and you don't
have to worry about the mixed waste issues for disposal.

A quick look at a summary of the states, statutes, and regulations that
we're going to be dealing with: RCRA (Resource Conservation Recovery
Act) dealing with landfills and hazardous material disposal; Safe
Drinking Water Act, specifically in this case, the Underground
Injections Control regs potentially for disposal of these kinds of
residuals; Atomic Energy Act, Nuclear Regulatory Commission regulating
radioactive materials; Clean Water Act, we're going to talk about that
because of the possibility that there's a liquid waste stream that may
be disposed of either by a discharge permit or to discharge to a POTW;
DOT Regulations because you can't move a waste (in some cases) if it
triggers a regulation of the DOT; and then the big player, state
requirements. State requirements are gonna be the ones that ultimately
control these issues, but don't forget there are numerous federal
regulations. A point of interest is that no federal waste disposal
regulation specifically mentions TENORM, and those definitions can vary
among the regulations. An example of that is DOT and RCRA. RCRA defines
hazardous waste and DOT uses a different definition of hazardous, it's
more of a plain meaning, dangerous waste. State and local waste disposal
facilities may have additional requirements and in fact the may is not
necessary there. They will have additional requirements, they'll need to
have additional requirements to be responsive to their needs.

RCRA. First of all RCRA of course, defines a solid waste and then
defines hazardous waste so it will control the identification,
management, and disposal of solid waste, including sludge. That means if
you generate a solid waste, by definition under RCRA, including drinking
water sludges and drinking water treatment plant sludges, you must
determine whether the waste is hazardous. You're going to use chemical
methods or you're going to use other methods, but specifically you're
either going to look for a listed waste or you're going to be involved
in the TCLP procedure. That's the toxicity characteristic leaching
procedure to determine whether or not the waste you have will trigger
the determination of hazardous. All waste then that exhibits that
toxicity, corrosivity, reactivity, or ignitability or is listed
specifically is going to be a hazardous waste. The requirements for its
disposal will depend on the amount produced monthly and the amount of
the hazardous waste stored. Remember there are several categories: large
quantity, small quantity, and conditionally exempt small quantity. Those
depend on weight in kilograms produced on a monthly basis and held on an
annual basis. A really important issue here to remember is that with
hazardous waste as defined under RCRA, your liability remains. So it is
important for systems to make this determination, make it correctly, so
that they can correctly dispose of the waste, if in fact they trigger
these requirements.

This slide just very quickly shows that RCRA Subtitle C, which deals
with hazardous waste and in fact controls low-level radioactive waste
landfills. Also Subtitle D, which controls landfills in general. That's
where you can find the requirements for the disposal facilities that may
be able to dispose of a waste that you produce in the process of
treating water.

The Clean Water Act, directives charged under NPDES, most states have a
delegated program. Montana has the MPDES, Montana Pollutant Discharge
Elimination System permit. It's a permit that may allow a system to
discharge the liquid waste stream directly into receiving water. The
other possibility is that you may be able to discharge your waste into a
publicly owned treatment works (POTW). This also can be done only with
the permission of the POTW and likely through a pre-treatment permit to
control the content of that waste and the quality of that waste. Federal
NPDES regulations don't set specific limits on radionuclides. That means
that states that operate programs, if they are to authorize NPDES
discharges and disposal, will have to set those limits. One of the
biggest considerations may be anti-degradation in terms of radioactive
material rather than specific limitations related to health. EPA
regulations on use and disposal of sewage sludge do not currently cover
radioactive material, so again you're going to see states taking the
burden, if they allow this kind of disposal, and describing the
appropriate conditions of that waste upon disposal. The Clean Water Act
states systems should always contact the NPDES program to determine
whether their system needs NPDES or other permit, they should also
contact the POTW to insure that the waste will be accepted. Also,
understand that POTWs aren't required to accept any waste and they will
have conditions for the disposal of a waste.

Safe Drinking Water Act considerations. I mentioned earlier underground
injection control (UIC), and we had a small section on UICs. EPA is
required to develop minimum requirements for UIC programs. There are 5
different kinds of underground injection wells and we'll have a brief
presentation on that later in the program.

DOT will regulate the transfer, transportation of materials, shipping,
labeling, and transport. DOT defines hazardous to include radioactive
materials, and again I must remind you that this is not the same meaning
as hazardous waste under RCRA. DOT does have some exemptions in their
requirements for the kinds of waste that might be part of water
treatment plant waste. DOT exempts certain kinds of materials provided
the concentration does not exceed 10 times the activity concentration
presented in table at 49 CFR 173.436. Just as an example, uranium that
we talked about earlier \[phone rings in\] seven picocuries, radium 226
and 228 are listed at 270, that means 10 times that number can occur in
a waste before DOT requires licensing. The Atomic Energy Act regulates
development and use of nuclear facilities; and the creation, generation,
and disposal of source, special nuclear, and by-product material.
However, as we mentioned earlier, uranium and thorium although they are
source materials do enjoy an exemption. They enjoy the opportunity to be
determined to be unimportant quantities of waste depending on the
possibility that the waste can meet the 0.05% by weight limit that was
mentioned on an earlier slide.

TENORM regulations are going to be principally in place by the states.
According to this slide, 13 states regulate TENORM as a general
conceptual group of sources of radioactivity. Each state will be
somewhat different. Many states will not have any regulations in place.

Residual types are going to be both liquid and solid. We're going to
look at the different kinds of treatment processes for the kinds of
waste that are either in a liquid stage or solid stage, and what kinds
of disposal options might be worth looking into. Waste streams might
include for the liquid phase, brines, in exchange salt, backwash water
from filters, rinse water, acid neutralization, and concentrate
regeneration from media. Solid waste that you might see will be spent
resins, spent filter media, spent membranes or failed membranes, and
sludges that might accumulate, either intentionally or unintentionally
in your treatment process. This table will give you an opportunity to
see what the likely or predicted kinds of waste will be. You see over at
the left hand side of this table, ion exchange (IX), is going to have
spent resin and media in terms of solid types of residuals, solid phase
residuals. With reverse osmosis (RO) you have spent membranes and the
membranes will fail or they'll foul and need to be replaced, and so on
down through the column. This is a good slide to keep an eye on later on
and refer to when you are looking at a particular water system and
trying to decide what kinds of waste it may have. The table is similar
for liquid residuals. The same list of technologies down the left hand
side indicating that for example the top one IX, there will be a brine
waste. There may be a backwash and there will be a rinse water. For RO,
there will be a concentrate. Of course RO concentrates the waste that it
removes from the water supply and that will have to be disposed of
periodically. Again take a look at that slide when you have an
opportunity and use it as a reference.

Disposal options. Direct discharge, discharge to a POTW, underground
injection, and landfills for solid waste. Here you have a chart that
integrates the possibilities, residual waste liquid down the left hand
side, liquid sludge, spent media, and spent membranes and the options
disposal. This does not mean in any particular situation we know or
anybody else knows that you will be able to get a permit, but it is
worth examining the possibilities. You may also be able to discharge a
liquid to a POTW, or you may be able to recycle, or use an underground
injection well.

Other options. Don't forget that when you look at other options for
treatment or handling of your waste stream they might include
incineration, evaporation, or sludge dewatering. Remember any of these
are going to have intermediate steps. For instance with incineration,
you may dispose of some portion but you will have a residual stream in
the form of air emissions. With evaporation ponds, you may have a
residual waste stream in the form of sludges that accumulate in the
bottom of the pond. Keep in mind that these are the options, but
intermediate processing options will also involve the production of some
kind of waste at some point that has to be disposed of. And then of
course there is land spreading or soil mixing which is being practiced
in many states for sludges in water treatment plants and waste water
plants. EPA says be very careful about that, make sure that the
demonstrated benefit is there and that the potential risks when you have
a waste that may have radionuclides or hazardous waste that those risks
are looked at and weighed against the advantages of using that kind of a
disposal system.

Liquids. The Clean Water Act of course, controls the discharge of
liquids, but it's important that you know whether or not you have an
accessible and appropriate receiving body, in other words, if you have a
surface water that's nearby, that's the first step. If it's hundreds of
miles to a surface water that could accept the waste, then of course,
this isn't an option. And then if you're going to discharge to a surface
water, you need to have a NPDES permit. Keep in mind that federal NPDES
regulations don't set specific limits on radionuclides. That's why I
mentioned earlier that you're going to be dealing with states. States
are going to have to be responsive to this if they are going to allow
this kind of disposal. State anti-degradation policies will also be
important.

Liquids discharged to a POTW. You're now stepped up from discharging
directly to a receiving stream. You're now considering discharging a
liquid to a POTW. Since the POTW will have to have a NPDES permit for
its discharge, a system that wants to discharge into a collection system
may need a local permit and a contract. Remember both the system, the
water system and the POTW are going to remain responsible for making
sure that anything that's introduced into their collection system
doesn't interfere with the POTW treatment process, somehow contaminate
the sludge, or violate the POTW's NPDES requirements. The likelihood is
that if you discharge into a POTW's collection system, you will need to
meet technically based local limits and we are again dealing with local
or state requirements for the control of these kinds of contaminants.
Keep in mind POTW's can refuse.

Solid residuals and landfills. The important determination is whether
the waste is hazardous. That means you have to go through the steps that
we mentioned earlier, look for it as a listed waste, look for results of
toxicity characteristic leaching procedure (TCLP), and obviously, if the
waste contains free liquids, you'll have to use the paint filter liquids
test. You may have to conduct intermediate processing if there are free
liquids because free liquids can't be discharged into a landfill. There
are no federal requirements to test residuals for radionuclides and no
federal regulation governing landfill disposal of water treatment plant
solids or sludges containing TENORM. So, again, you're looking at a need
for the states to fill in the gap here if you want to provide this as a
method for disposal of these kinds of wastes.

Solid waste landfills. The municipal solid waste landfills can accept
non-hazardous, solid, or TENORM from all water systems, subject to
approval from that facility. Industrial solid waste landfill may also
accept non-hazardous solid TENORM waste. Again, subject to landfill
approval and the approval of, and compliance with, local and state
requirements. Hazardous waste landfills are likely to be able to accept
waste from all generator classes. Some have explicit permit conditions
while others may have to request state approval before accepting the
TENORM waste.

Complex radioactivity containing waste. Low-level radioactive waste
landfills are going to be licensed by NRC or a state under agreement.
There are a couple of them mentioned here in this slide. Barnwell, South
Carolina, however, soon will not accept waste except from South
Carolina, Connecticut, and New Jersey. Richland, Washington operates an
LLRW landfill and accepts certain types of TENORM waste from all states.
Another LLRW landfill is Envirocare in Utah. These last two slides are
the decision trees for both the solid residual disposal and the liquid
residual disposal. I encourage you to spend a few minutes with these
slides. These are good useful slides. You start on this slide in the
upper left hand corner and just follow through with what you know about
the waste. When you come to a square where you don't know the answer,
that's the time when you need to do further investigation or analysis to
determine the answer. It will take you through from identifying the
quantity and quality, to knowing what possible options you have for
disposal. The next slide, of course, is the tree that deals with liquid
wastes. There is crossover between these two decision trees. Again,
don't try to do this in one or two minutes. Spend some time, read
through these carefully. Decision trees are a nightmare unless you are
willing to spend the time to work through each and every square and
unless you're willing to stop at a square where you don't know the
answer and accumulate the information you need about your waste stream
to allow you to continue through the decision tree.

That finishes up my presentation. We did get some questions. One
question says, "Will sewage treatment plants that receive waste from
drinking water treatment plants have to amend their discharge permits if
there are no federal or state discharge limits for uranium?" This is an
excellent question and the answer is that sewage treatment plants, if
they want to be responsive to these kinds of wastes, will have to
determine what the most effective way is for them to control
contaminants discharging from their system into the receiving water.
This may mean applying additional NPDES limits at their discharge or
applying technically based local limits upon the system that discharges
into their collection systems. Another question came in. "If sludges
must be dewatered prior to disposal, will the dewatering equipment have
to be decontaminated after each usage?" This is another good question.
Obviously, the answer can't be given without knowing the characteristics
of the waste, but it's a good question because it indicates the person
that asked it is thinking about the possibilities for problems with
handling the waste. Obviously, this is one thing you're going to have
consider when you look at your waste and the concentrations of your
waste. State and local governments are going to have to come up with the
appropriate kind of control on this to answer this kind of question in
their day-to-day operation of sludge management equipment. And that
finishes up for me. Thank you.

**Andrea:** Thank you, Kevin. Really appreciate it. I think before we go
on, I just want to ask if our other speaker, Dennis Clifford, came on.

**Dennis**: I screwed up.

**Andrea:** That's OK. We had some technical difficulties at first, so
Dennis we're going to put you at the end, OK?

**Dennis:** That's fine with me, but since the talk is about treatment,
then you can stick me in anywhere, the sooner the better.

**Andrea**: Margaret, can we stick him now. Can we load up Dennis'
treatment options?

**Margaret**: Sure.

**Andrea:** That's great.

**Margaret:** All set.

**Dennis:** Well, OK. You see it here, Fundamentals of Radium and
Uranium Removal, that's the title of the talk. We're removing radium 226
and 228 from water supplies. There's also some radium 224, but this
decays away rather rapidly. Mainly, we'll be focusing on radium 226 and
228. Radium 226 is an alpha emitter, with a 1,600 year half-life, and
228 is a beta emitter with about a six year half-life. With respect to
uranium, we have two isotopes that are of significant interest. That is
uranium 238 which is an alpha emitter, this is the one on the top here.
And uranium 234, which is also an alpha emitter and if those are present
at their naturally occurring abundance, about half the radioactivity in
the water will be due to uranium 238 and the other half to uranium 234.
If these are present at their naturally occurring abundance, one
microgram of uranium is approximately .67 picocuries.

Now, this slide just says that the chemical and physical chemical
behavior of all those isotopes is essentially the same, although you can
separate uranium 238 and 235 physically/chemically, for all practical
purposes, the removal of isotopes 226 radium and 228 are the same. For
example, 95% removal of radium 226 and there's also 95% removal of
radium 228. The same is true of uranium on the mass basis and an
activity basis, the removal will be the same.

Now, this slide shows the radium and uranium speciation in ground water
as a function of pH. We're looking at the middle column the predominant
species. For radium, at all pH's, it's a divalent cation, whereas
uranium and let's focus on pH as of interest to drinking water supplies,
at 6.5 to 7.6, uranium exists as the uranyl, that UO~2~ carbonate C03,
that's a dicarbonate complex with a 2- charge. It's a divalent anion.
And above pH 7.6 uranium exists as a tricarbonate anion, which has a 4-
charge. The 2- and 4- charges are reasons why uranium is so easily
removed from water by anion exchange and why the anion exchange resins
are so easily regenerated. There's one note here that above pH 10.5
which has really nothing to do with water supplies, but which if you use
a lime softening in high pH, you'll find that uranium exists as a
positively charged uranyl hydroxide complex which then is removed by the
magnesium hydroxide precipitate that exists at that pH.

So, here are the radium removal methods. Cation exchange softening is a
best available technology listed in the regulation. The reaction is,
this is basically a softening reaction. Two resin sites in the sodium
form when they contact a radium ion and solution. The radium will go on
to the resin, take two resin sites and give up two sodium ions. The
predominant reaction going on there though is that the resin in the
sodium form plus calcium or magnesium is going to release the sodium.
The radium has a very high affinity for cation resins and so if you're
removing hardness, you're also removing radium for sure.

Lime softening is the addition of lime typically to precipitate calcium
carbonate and at higher pH's to precipitate magnesium hydroxide. It also
removes radium.

Reverse osmosis work very well for removing radium. It's expensive. We
did a good deal of research on the adsorption of radium onto manganese
oxides. Rich Valentine at Iowa also did work on this. It's a very good
method for removing radium at very low concentrations of manganese.

Precipitation with barium sulphate is also used. \[audio cut out\]
Another method is adsorption of radium onto barium sulphate impregnated
media and there's two kinds of media that we worked with. One is the
so-called Dow complexer that had barium sulphate in cation resin, and
the other is barium sulphate loaded activated alumina. In that case, the
radium goes onto the barium sulphate that is fixed on the media.

Electrodialysis is a membrane process similar to RO except that in
electrodialysis the ions move through the membranes rather than the
water. It's also very effective and has the same issue with brine
disposal as RO.

Now, for point-of-use. RO is listed as a BAT for radium removal, but
cation exchange softening is quite applicable for small
systems/household systems. In fact, most resins used in the state are
probably in water softeners in homes. Adsorption onto manganese dioxide
impregnated filters is a method that's quite effective. A small
cartridge filter that's impregnated with manganese oxides will remove
radium very effectively and adsorption on barium sulphate impregnated or
alumina, again, this is the same as the full scale system, but done a
small scale.

Here's a picture of a radium removal ion exchange system with bypass
blending of the raw water. In the case of softening and radium removal,
we don't have to remove radium down to zero, we can go from ten down to
four picocuries per liter for example. Water would be passed through the
resin, which is sodium-form strong acid cation resin and exchange
radium, calcium, and magnesium for sodium. Then the hardness free water
comes out here at the bottom of the column and the bypass raw water is
blended with it to produce a product water that has the right hardness
and radium level. The radium contaminated waste brine which is produced
by sodium chloride regeneration is sent to the sanitary sewer if it's
allowed.

The ion exchange resins for radium removal, one shown here, is standard
strong acid cation resin with sulphanate exchange groups is typically
used.

Here's what's called a breakthrough curve from a softening system. This
is the magnesium, the calcium, and radium as they come out of the end of
the column breakthrough for ion exchange softening. So on the Y axis, we
have calcium and magnesium and then on the other Y axis, we have radium
and then way down later around 2000 bed volumes comes radium. So radium
has an extremely high affinity and if you're removing magnesium and
calcium, for sure you are removing radium. Now, in the first run, we can
get 2000, 4000 bed volumes of run length, but then after salt
regeneration, we find that radium breaks through with magnesium. So,
basically these systems that are removing radium are water softeners.
They're operated as softeners and when the hardness breaks through,
that's when the radium run stops. And if that's the case, here's a
little box on the bottom that says, if the feed water contains 10
picocuries per liter of radium then the resin is going to contain about
20 picocuries per gram at steady state. I mean after five regenerations
you'll come to steady state and, at that point, you'll have about 20
picocuries per radium per gram. And the waste brine typically will
contain about 600 picocuries per liter of salt.

Here is the process flow schematic for radium removal by adsorption onto
preformed manganese oxide. We did work at the University of Houston and
as I mentioned Rich Valentine in Iowa did a lot of work on this method
of radium removal. Here, it shows in a typical small system where the
feed water would also contain things like iron and manganese and we'd
remove that using typically air, chlorine per manganese in a filterous
system and then in a mixer we would add the preformed manganese oxide,
which is made by reacting per manganate with manganese sulphate to
produce manganese dioxide. It absorbs the radium immediately and at very
low dosages of manganese and then it's filtered either on a diatomaceous
or a multimedia filter or membrane filter. Alternatively, barium
chloride may be added to precipitate barium sulphates. So instead of
adding manganese, (which is black by the way, and this could be a
problem in some systems, and a white precipitate is a little less
troublesome sometimes) barium sulphate is also quite effective in this
system.

Here's some work that shows some radium removal as a function of the
dose of manganese dioxide. This is a Houston groundwater that we spiked
with radium to bring its level up to either 25 picocuries per liter or
13 picocuries per liter and what this graph shows is this percent radium
removal on the Y axis and then on the X axis the dosage of manganese
dioxide measured as manganese. And you'll notice, too, here at .2
milligrams per liter of manganese, we're getting 50% removal regardless
of the level of radium in the water, either 13 or 25 picocuries per
liter. So this estimate said that if we need to get 50% removal, for
example, water contains ten picocuries per liter and we want to reduce
it to five, the residual dry manganese dioxide solid dried would
completely contain 21,000 picocuries per gram. This is an enormous
level, but then again, there's only 2/10 of a part per million of this
material. It's very effective, but then the radium is highly
concentrated on the waste.

Next slide shows the breakthrough curve for the so-called Radio-radium
Selective Complexer which is a barium sulphate loaded cation resin. Just
impregnate the resin with small particles of barium sulphate which is
effective for absorbing the radium. In this case, the feed radium was
about nine picocuries per liter and the effluent was zero until about
20,000 bed volumes and then it gradually came up to around nine at 60,
70, 80,000 bed volumes. Now, for those of you who don't know the term
bed volumes. A bed volume is a volume of fluid equal to the volume of
resin or media in the bed. It's sort of a dimensionless way to look at
breakthrough curves. So, this material has a very high capacity for
radium. In fact, that's one of the reasons I think Dow quit making it
although it may still be available. They had problems disposing of the
waste.

For single column operation, single column because with a breakthrough
curve like this, one would normally use two columns in series and then
exhaust the first one completely. But if we have a single column and ten
picocuries per liter in the feed, the spent resin is going to contain
about 500 picocuries per gram of resin. Dry resin.

This one shows the breakthrough curve for plain and barium sulphate
loaded aluminum and on the Y axis is the ratio of the influent to the
effluent activities, so 0.5 here is 50% removal and 0.8 is 80% removal
or excuse, 80% remaining and 50% remaining and so forth. Now, typically
then, if we have ten picocuries per liter in the feed, we'd like to get
50% in the effluent of that, that's about 5 or less, so we can have a
run length approaching 40,000 bed volumes and this is an activated
alumina that has been deliberately doped with barium sulphate in a
method we described some years ago in an EPA report. The plain aluminum,
activated alumina instead of getting 40,000 bed volumes is going to get
more like one or two bed volumes, but it will work and one or two bed
volumes is not bad actually just for removing a contaminant in an under
the sink type unit.

Uranium removal methods, we jump onto those here and move. The best one
is anion exchange; it's the best available treatment. And in this case,
we have the anion resin which is shown here as resin in the chloride
form. Four sites, that is four fluoride sites, contact one uranyl
carbonate complex, which is a 4- \[unintelligible\] and uranium goes on,
the carbonate complex is on and chloride comes off. This uranium
carbonate complex because of its 4- character has an enormous affinity
for the resin. And we can get very, very long run lengths.

Another method, as with radium, is lime softening. Lime softening works
very well for uranium removal.

Enhanced coagulation, this would be coagulation with a pH adjusted to
the proper means and the dosage to the proper dosage and that's
coagulation with iron or aluminum, that is alum or ferric fluoride or
ferric sulfate, it's considered the best available treatment. RO is a
BAT also. Activated alumina works pretty well and electrodialysis works
as well as RO in membrane processes. But for point-of-use, there's, to
my knowledge, no listed POU for uranium removal. Anion exchange is going
to work extremely well in under the sink or a point of entry system
would work very well for removing the uranyl carbonate. RO works, of
course, and activated alumina works reasonably well.

This slide shows the affect of pH and coagulant on uranium removal at a
dose of 25 mg per liter. On the Y axis it's the percent of uranium
that's removed and on the X axis it's the pH. You see at pH 6 you can
get typically almost 90+% removal using alum and ferric as iron 3. Iron
2 is not quite so good. Then, at pH 8, which is where we probably prefer
to operate in this range that removals are considerably less and if we
get up to pH 10, which is where uranium starts to have a positively
charge hydroxide complex, we can remove it in these processes. And
little box on the side here says it's for 50% removal of uranium which
is at a level of 40 micrograms per liter, the dry sludge is going to
contain about 800 picocuries of uranium per gram of dry iron sludge.

Now, here's lime softening. This is precipitation at high pH as
contrasted with the last one which is generally lower pH, either 6 or
even 10. This shows the effect of pH and of course, lime dose because as
the pH increases, the lime dose increases. The effect of pH on uranium
removal by lime softening and you see that on the Y axis, we have %
removal. As the pH increased from 9, 10, or even 11, the removal
increases rather dramatically. It's at these high pHs, especially when
there's magnesium present, that this magnesium hydroxide is a surface
unto which the positively charged uranium complex is removed. So you get
really good removals up here at really high pHs, but you can get decent
50% removal even at pH's 9.5 and 10. If we're talking about a 90%
removal of a 40 micrograms per liter feed water, the dry sludge is
approximately going to contain 130 picocuries per gram of calcium
carbonate.

One of the questions that was asked previous to this, I will answer it
now. "Are there any resins that are better for uranium removal?" The
best resins are like in the middle here, Type 1 macropourous resins.
Type 1 means it's got this trimethyl group on the nitrogen exchange
group and we use Ionac A-642, there's equivalent resins over here,
Durolite and Amberlite resins.

This slide show the uranium removal during anion exchange. This is
uranium concentration in the effluent and this is the number bed volumes
and where, as I said, we were running water softeners to 300 bed volumes
typically for softening. We can run, if you're just removing uranium on
an anion resin, you can run at several hundred thousand bed volumes.
That would be maybe a thousand times longer because it has such an
enormous affinity for resin. And, in this case, the work was done in
Chimney Hill, which is not too far from Houston. It's a subdivision and
the water there contained about hundred micrograms per liter on the
average of uranium. And, so, you say that basically there's no uranium
until it gradually breaks through. Normally, we do not run these, even
though we could run to several hundred thousand bed volumes, we have
problems with pressure drop, particle filtration, algae growth, in fact,
in we did these columns in the light. We have a sort of a rule that, not
a rule really, an observation that 30,000 bed volumes is what I think
Tom Sorg worked with some places out in California where 30,000 bed
volumes was typical run length. I've seen that elsewhere, so if the feed
water contains about 40 parts per billion of uranium, the waste will
contain about 80,000 picocuries per liter for 30,000 bed volume run
length. And again these systems are regenerated with sodium chloride,
the same as a water softener. This anion resin removal system is
basically a water softener with anion resin in it.

This slide shows the effect of the uranium concentration and sulfate and
chloride concentrations. It's kind of a complicated slide, but just let
me tell you what it says. This is the run length on the Y axis and this
is the uranium concentration and this curve on the top shows that it's
decreasing. That as the uranium concentration increases, the run length
goes from like 800,000 down to where it was in Chimney Hill, about
350,000. And now if the chloride is replaced with, this water had no
sulfate in it, only 5 parts per million sulfate, but if sulfate's
replaced with chloride in this water, then the run length would be much
less because sulfate does, even though uranium has a high affinity for
the resins, sulfate is a better competitor than chloride.

OK, now to summarize in the last three slides. Treatment methods for
radium removal: ion exchange softening with sodium form resin using a
strong acid cation resin, got 95% removal when it operated to hardness
breakthrough and regenerated with sodium chloride. Barium sulfate
precipitation can get any removal really depending on how much is added,
but typically in the range of 50-95%. We add barium chloride to the feed
water because that's a soluble salt and barium sulfate precipitates.
Manganese dioxide adsorption. Again, getting 50-95% removal. We're using
preformed manganese dioxide that's made in a date tank and pumped in the
head of a filter or deep bed filter or precoat filter or a membrane
filter. RO, of course, is always great for removing big ions like this,
it's effective, but it's expensive.

For uranium removal, coagulation with iron and aluminum salts are going
to remove 50-90% at pHs of 6 and 10. Lime softening, typically 80-100%
or 99% removal. Higher pH means better removal and magnesium helps that
pH so it's greater than 10.6. Anion exchange is quite good. Better than
95% removal for sure for long run lengths can be hundreds of thousands
of bed volumes but we generally run between 10,000 and 50,000 bed
volumes and regenerate with 2-4 molar salts, that's 12-24% salt
solution. RO is, of course, effective here also.

This is the last slide, but I want to make this comment; the more
effective the coagulant, or the absorbent, the higher the radioactivity
in the residual. So I just wanted to summarize this and these are some
estimates that could occur in typical systems. For ion exchange
softening then for radium removal, we can have 600 picocuries per liter
in the brine and 20 picocuries per liter per gram on the resin. For
coagulation filtration with hydroxides for uranium removal, we can get
enormous levels, like here's 21,000 picocuries per gram. Iron
coagulation filtration for uranium removal is going to get 800
picocuries per gram. Now, these are dry grams, completely dry, I mean
these are just calculated values. There are no such measured values, but
these are based on calculation. Anion exchange for uranium removal is
80,000 picocuries per liter in the spent brine and based on a 30,000 bed
volume run length.

So, that ends the presentation. There's one question that was asked in
the preliminary material I received from the states, "Are there specific
resins for uranium removal?" Yes. Macropourous, strong base resins of
the type that I mentioned in here are better than others. Someone asked,
"Are there any surrogates that can be analyzed easily on-site for
uranium removal?" Well, it's really not necessary because these columns
are going to run for such a long time. Uranium is the last ion to break
through and so you probably don't need a surrogate. The column may be
plugging up with fines before it actually runs out of capacity for
uranium. And, "Are there any demonstrations or reports available?" Yes,
we have some. I can't really give you chapter and verse now, but I can
send it to Andrea or somebody at EPA and they can send it. We have a
number of papers and reports on that subject. That's it.

**Andrea:** Thank you very much. Let's go on to our next presenter and
that's Robyn Delehanty. She's from the Office of Groundwater and
Drinking Water here in D.C. and will be talking about UIC and disposal
of radionuclide residuals.

**Robyn:** Hi, everyone, I'm here with Bruce Kobelski, also from our
office, whose specialty or expertise is in deep well injection. So, if
there are any deep well injection questions that come in, he'll be the
one to answer those. I think as Kevin said earlier, we're under the Safe
Drinking Water Act. The Underground Injection Control (UIC) Program was
required to develop minimum federal requirements for states and tribes
for their own UIC programs. The purpose of our program is to protect
underground sources of drinking water. To date, there are 33 states that
have applied for and received primary enforcement capabilities. In
addition to that, there's 17 states where EPA runs the entire program or
a portion of the program. Actually seven of those states are shared
program responsibilities between states and the federal EPA. Again, as I
said, our mission is to protect underground sources of drinking water
which include current and future sources of drinking water. Basically we
are looking at ground waters that are less than 10,000 total dissolved
solids (TDSs), and that have a capacity to serve a public water system.
So, these are the ground waters we are protecting.

OK. Briefly, the requirements for these wells, these wells were broken
down into five classes and these classes are based on their
construction, their function, and on their operating features. Class I
wells are deep wells. They're technical, they're highly regulated and
they receive hazardous waste, industrial waste and municipal waste.
These wells are largely about a mile deep, and there are 500 of them
nationally. Class II wells are related to oil and gas production.
They're wells that reinject brines and other waste fluids that have come
up in association with oil and gas production. They're also used for
enhanced oil recovery, that is, they inject fluids to stimulate
production wells and enhance the recovery of the oil from that
formation. Currently, there are over 140,000 of these Class II wells.
Class III wells are wells that are associated with the production of
mining production, such as salt and uranium. Class IV wells are
conspicuously absent because they're banned. They were banned in 1984
because they allowed for the injection of hazardous waste into or above
underground sources of drinking water and now are only allowed in
conjunction with cleanup activities at RCRA, CERCLA, and state approved
cleanup sites. If you don't fit into Class I, II, III, or IV, you are in
Class V. This is kind of the catchall category. These wells are largely
shallow injection wells, septic systems, dry wells, though you can have
wells that are also very deep, but they're just uncommon. To give you an
idea, there's anywhere between 500,000-650,000 Class V wells.

OK. So, before you consider the UIC program, an important thing is to
understand what your waste characteristics are. It's dependent upon
these as to what type of well might be applicable for receiving your
waste. So, the first thing is to determine whether it's radioactive,
hazardous, or non-hazardous. And just so everyone is clear, under the
UIC regulations, we are using the radioactive definitions as found in
RCRA. OK. So, again, and we've talked about these before, but I've just
listed these levels for you here.

Another thing to consider is that the UIC program does not regulate
single family residential septic systems. They are excluded from
regulation. However, at the same time, the Safe Drinking Water Act under
1431, gives the UIC program the authority to act in any situation where
there is an imminent or substantial endangerment to public health based
on a fluid that's being injected. So, that's a little caution for
point-of-use of systems. We don't regulate single family homes, but if
concentrations were high enough to cause that imminent and substantial
endangerment, action could be taken.

So, if you want to consider using the UIC program, Class I would be an
option keeping in mind that there are a limited number of these wells
and they're deep injection wells below the lower most USDW. Some
considerations, they're very stringently regulated. There are not a lot
of facilities that are able to accept this offsite waste, meaning that
many of these wells are constructed by facilities and are only permitted
to accept waste from that facility. So, there's a limited number that
can accept offsite waste. They are allowed to take slurries and solids
only in limited circumstances, and that has to do with the operation of
the well. They're very expensive to construct so it's unlikely that an
individual public water system would be constructing one of these wells.
Class II wells, again, are oil and gas related and by and large, they
only accept those wastes that are generated from the production of oil
and gas. I will say that there's one exception and that is when there's
enhanced oil recovery -- or when they're stimulating the formation to
produce more oil. However, again, the fluid that they accept can impact
that formation and so the owners of these wells are very cautious about
the types of fluids that they will accept. So, again, it's unlikely that
it could go into a Class II well. Class III are mining related, so this
would not be an option. Class IV wells are banned and so they also would
be not be an option. Class V wells, which are the most numerous type of
injection wells, would not be an option if you have a hazardous or
radioactive waste. Again, these are shallow disposal systems by and
large, and they are injecting into or above drinking water resources.
There's a protective standard and you cannot exceed any primary drinking
water standard or otherwise adversely affect public health so there's
probably limited use of this well type. If you would like more
information, we have a couple websites here listed, this is Safe
Drinking Water Hotline, and Suzanne Kelly in our office is the one who's
taking the lead on this drinking water treatment residuals and the UIC.
And let me just check for a minute and see if there's a question.

**Andrea:** OK. We're going to go ahead and see if we had any emails
that came in. Well, it looks like we have one that came in before from
one of the states. Would you like to read the question?

**Robin:** Sure. I'm going to hand this one over to Bruce because it's a
Class I question.

**Bruce:** One of the questions was, "it sounds like Class I wells might
be an option and how do you find out if there is a Class I well around?"
I think the best answer here is there's nine of ten EPA regions that
have Class I wells, so the regions would be a great source to contact.
Also your primacy states have a UIC program that they definitely know
the information about where their Class I wells are located. If
anything, although we have 470 something odd Class I wells, we do have a
good handle as to where they're located and what wastes they may be
willing to accept and what their permit conditions are. So, you can
contact the states or regions for information and one thing I might
point out too, on our website, the Safewater/UIC Website, there's a
report that you could download on Class I wells. You just click on it
and you'll be able to download it. Probably there's more than you really
care to learn about Class I wells, but there is a lot of reference
material in there that you may be able to pull from and find
interesting.

**Andrea:** Great Bruce and thanks, Robyn. I think we'll just go ahead
to our next speaker and that's Norm Hahn from the Department of Natural
Resources in Wisconsin. So, whenever we get your presentation loaded up,
I think you're ready to go Norm.

**Norm:** Thank you. Hello, I would like to briefly summarize our
experiences in Wisconsin in removing and disposing radium in the
community water system. I've broken it up by municipal and by other than
municipal (OTM) and how many violations we have of each kind. Currently
we have 34 combined radium, seven gross alpha only and two uranium
violations. \[audio problems\]

**Andrea:** Hello Norm?

**Norm:** Yes.

**Andrea:** We can barely hear you.

**Norm:** Can you hear me better now?

**Andrea:** Yes. Is there a speaker phone next to you, Norm?

**Norm:** Can you hear me now.

**Andrea:** Yes, please proceed.

**Norm:** OK. Sorry about that. In Wisconsin, we currently have 34
combined radium, seven gross alpha only, and two uranium violations.
On-going sampling may result in several additional violations. I've
broken them down by municipal and OTMs on the slides. In the past, we've
probably had about an additional 10-20 violations that have been taken
care of over the past 20 years. The systems taking action, normally
they're taking action with some other part because they have an iron and
manganese problem, a softening, a hardness problem or they're replaced
by surface water. There are other radionuclide reduction methods that
are currently being used in Wisconsin. We have a number of systems that
are either going to replace or blend with surface water and we have a
number in the Green Bay and Milwaukee area that want to do that. There's
also an issue with diversion of water over the basin divide from Lake
Michigan to \[audio cut out\]

Can you hear me better now? OK. I apologize for any problems on our end
here. A number of our water systems are facing the question of whether
to continue to mine water from the deep sandstone aquifer or to try to
get water in a diversion from the Lake Michigan basin. That's an ongoing
political issue here in this region of the country. A number of systems
will also be replacing or blending with low radium content groundwater
where they have the ability to do so where they have multiple aquifers.
Then the existing treatment, some of them have been in service for
years, mainly for hardness removal or newly approved radium treatment
methods of cation exchange softening or lime softening. I think we have
2-3 plants that are doing that and we have one \[?\] filtration plant
that's been in existence since the 80's. We have two newly approved
anion exchange for uranium removal plants here in the state. Those are
smaller villages in the northern part of the state. They are disposing
of their wastewater to a sanitary sewer. One of them just went online, I
believe, and because it does such a good job, as Dennis was saying, of
accumulating the uranium, they have to backwash, and regenerate fairly
frequently.

We also have a number of systems that have either completed or are in
the process of piloting some radium reduction methods here in the state
and those include two types of radium selective complexers or radium
selective media, the kind that accumulate radium but then you cannot
regenerate it or backwash it off. That's the Down Company radium
selective complexer, which is marketed by Lane Northwest in this state.
Also the WRT Company, Z88 selective resin. We have several systems that
are piloting and are looking at HML filtration. We also, historically
and recently, have had several systems look at doing some geophysical
logging of their wells to hopefully isolate hot zones where the
groundwater \[pause\]

Excuse me, someone interrupted. Several systems that were looking at
doing the geophysical logging and then putting in liners or packers or
disks to hopefully zone off those highest radium proceeding formations,
but that hasn't been real successful and if it is going to work, it's
probably for systems that have violations of just directly over the
standard. We also have one system that looked at EDR and reverse osmosis
on a piloted basis. This department, the DNR and our Department of
Health and Family Services, one of our sister departments, which
contains the radium protection section, have worked together closely to
come up with practical radionuclide waste disposal guidance. Given that
the issue is not largely addressed (as previous presenter kind of showed
that), we're kind of been on our own to some extent. So we've worked
together to come up with practical guidance that would kind of fill in
the holes. As I said before, we've been working on this since the early
'80's when radium enforcement first started. We have in our tool and
have put in criteria. We've looked at, because so much of our POTW
sludge is land spread, we have looked at coming up with criteria for
land spreading sludge, including water treatment plant lime softening
sludge that contains radium and I'll talk about that more on a future
slide. We have some criteria that we've updated. Kind of a guidance
paper for consultants and utility people that we updated in March of
this year and if anyone would like a copy, they could contact me and I'd
be happy to provide them with a copy. In our state, any resins that
accumulate, like the DOW's, RSC or the \[?\] media, because they
continuously accumulate the radium, it will become a low-level
radioactive waste. They are required to have a license both for the
pilot and any final plants - for operating a plant and for disposal at a
low-level radioactive waste site that would be out of this state.

And, one issue is that even though treatment in a number of systems is
for radium removal, the fact of the matter is that the sludge at the
POTW is already seeing that same approximate concentration. So, it's not
like they're handling a new problem. We have got to make sure we're
managing an existing problem correctly and treatment generally, unless
you're removing the radium through a selective complex or something like
that, you're still going to see approximate concentrations in the
wastewater treatment sludge where the radium and/or uranium is coming
out. What we've done in the state is we've looked in the back of our
radiation protection section code, there's an Appendix E that contains
the Code of Federal Regulations to see if our 20 criteria for disposal
of radionuclides through a sanitary sewer to a surface water body,
(i.e., a storm sewer) or directly to a surface water body, basically it
allows 600 picocuries per liter of radium going into a sanitary sewer
and 60 to a storm sewer or surface water body. But you can add in
because most of it comes out in the brine, if that's what you're using,
you can also add in the backwash water, the rinse water, and other
wastewater generated by the plant so that the average over the month and
over the year meets the criteria.

In our approvals, we look, going back at the last slide briefly. Every
time we look at a water treatment plant for removing radium or uranium,
we look at the issue of disposal, whether it's a solid or liquid and we
make sure that we approve it as a part of that process and also in our
approvals, we require that the media when it's spent or when it fails,
be examined for radionuclide content prior to its disposal. Now, when we
presented the landfill and solid waste disposal issue to our solid waste
people, they weren't interested in codifying those requirements due to
the work involved and because it's a roughly small part of what they
believe is their total workload, so we have still have criteria for
disposal of our TENORM waste to a landfill and anything that's between
50-2000 picocuries per gram by dry weight of content has to be reviewed
both by us and by the radiation protection section before we approve it
for disposal. Anything with a content of more than 2000 picocuries per
gram has to go to a low-level radioactive waste disposal site.

I thought you might be interested in seeing, because we do so much land
spreading, where does all our POTW sludge that contains the radium,
where does that go? 94% is land spread. 3% is fertilizer production.
2.5% is landfilled and 0.5% is incinerated.

And this is a quick summary of our NR Tool for land spreading criteria
where and this was also reviewed in addition by the radiation protection
council, which is now disbanded, but at that time was a group of experts
from around the state who were advisors to the radiation protection
section and for the legislature. Radium 226 is considered the
controlling factor due to its long half-life and because it gives off
radon gas which is a concern for future uses above the landfill or a
site that's being land spread, maximum 2 picocuries per gram radium 226
dry weight in the top 12 inches limit. The soil pH has to be greater
than or equal to 6. There has to be some minimum organic matter content
required in the soil so that when the sludge is applied, the radium
doesn't quickly move off the site and at 1640 microcuries per acre, the
loading has to stop and a site can be sampled to see what the radium
content if the theoretical calculations are exceeded. The people in
wastewater tell me that so far, no site has yet exceeded its land
spreading life.

We do not allow deep well injection here in this state. We do approve
it, especially for OTMs, disposal of cation exchange regeneration water
containing radium to a septic system if that's the only alternative.
Currently, we do not regulate for disposal of the sludge, we regulate
from septic systems, it's either land spread or it's sent to a POTW, but
the radionuclide content of that septic system sludge is not currently
regulated. And, our Department of Health, in conjunction with us, has
looked at two systems; one is a cation exchange softening plant, one was
the HMO's filtration plant looking for gamma radiation outside the
vessels containing the media and checking for radon gas, either when
hatches are opened or when units are regenerated and the backwash
regeneration water empties into the sump and some rise very quickly.
There was not much gamma radiation given off above background right
outside the shelves, however, radon gas was a concern either when the
tanks were opened or the regeneration occurred. There should be proper
ventilation and/or the operator should not be present in the room during
that time. That really concludes my talk. Apologize for any technical
difficulties if you could not hear me.

**Andrea :** I think we have time for a question, Norm, I really
appreciate you giving us this presentation. It's nice getting a
perspective from a state. Is there a question that came up?

**Norm:** I'm having trouble hearing you.

**Andrea:** That's OK. I'm looking to see if any questions came up
during your presentation and I'm not sure if they did. I think what
we'll do is if there are any questions, we'll answer them at the end.
So, right now, we'll just go on to our next speaker, Loren Setlow and
Loren is a geologist with EPA's Office of Radiation and Indoor Air. He
is presently Chair of the Naturally Occurring Radioactive Material
Subcommittee of the U.S. Government's Interagency Steering Committee on
Radiation Standards (ISCORS) and has been a member of the Sewage Sludge
Subcommittee of ISCORS for the last seven years. He also recently served
as Chairman of the International Atomic Energy Agency Technical Meeting
on regulatory approaches for the control of environmental residues
containing naturally occurring radioactive material. He has held
positions with the National Academy of Sciences, Congress' Government
Accountability Agency, USGS and the State of Massachusetts. So, with
that, Loren will be talking about worker safety issues.

**Loren:** Thank you very much, Andrea. Because radiation is invisible,
tasteless and odorless, it is commonly overlooked as a potential hazard
at water systems. Radiation exposure can present serious health hazards.
Systems need to determine whether a radiation problem exists and if it
does, take appropriate safety precautions to prevent or limit water
systems' staff members' exposure to radiation.

A system should contact a professional radiation protection specialist
or health physicist for assistance in conducting a radiation survey
if: 1) the system has had an analytical result within the last five
years that has approached or exceeded an MCL for regulated radionuclide;
or, 2) if calculations derived from use of the EPA's SPARC program
indicates potential concentrations of radioactivity in residuals and
filters in the system. A radiation survey can be conducted by using a
radiation survey meter to identify any points at which contamination
exists, using an integrating radiation measuring device to determine
whether exposure could occur over time or sampling filter media wastes
and water through further laboratory analysis. Some states require
radiation protection specialists or health physicists who conduct
radiation surveys, including radon surveys, to be certified or licensed.

Although designed for post cleanup surveys of radioactively contaminated
sites, EPA's multiagency radiation survey and site investigation manual
or MARSSIM provides useful information on planning and conducting a
survey of potentially contaminated surface soils and building surfaces.
The manual and other information on radiation surveys can be obtained
from EPA's radiation protection division website,
[www.epa.gov/radiation](http://www.epa.gov/radiation) and then MARSSIM.
We've heard some of this earlier, but water system workers are most
likely to be exposed to elevated levels of radioactive materials when
coming into contact with residuals, filter backwash and sludge, carrying
maintenance of contaminated pumps or piping or while moving or
transporting wastes and filters for disposal.

Possible sources of radiation include pumps and piping where mineral
scales accumulate; lagoons; flocculation and sedimentation tanks where
residual sludges accumulate; membranes and resin filters pumping
stations and storage tanks where scales and sludges accumulate; and
facilities where filter backwash, brines or other contaminated water
accumulates. Facilities that are enclosed present the potential for
enhanced radiation inhalation exposure, particularly from radon.
Exposure to radon can also occur at residuals processing or handling
areas at the system and offsite locations such as landfills where
residuals are shoveled, transported, or disposed of.

The three primary paths of radiation exposure at a system are
inhalation, ingestion, and direct exposure. Inhalation of alpha or beta
emitting radioactive materials is a concern because radioactive
materials taken into the body results in radiation doses to internal
organs and tissues such as lining of the lungs. Workers could inhale
radioactively contaminated dust or water droplets while dealing with
residuals or during normal filter operations like air scour, high
pressure water sprays, and backwash operations. Ingestions, or the
swallowing of alpha, beta, or gamma emitting radioactive materials is a
concern for the same reasons as inhalation exposures. Workers can ingest
radioactive materials if they fail to observe good sanitary practices,
including washing their hands before eating, failing to cover their
noses and mouths by wearing approved respiratory protection, and
swallowing contaminated dust and water droplets or eating and drinking
in areas where dust and water droplets could settle on food or drink.
Radioactive materials that emit gamma radiation are a direct radiation
concern because the gamma rays pose an external radiation exposure
hazard. Because gamma rays can pass through common construction
materials and most protective clothing, the distance between the
radioactive material and the person, as well as the time spent in
proximity to the material are factors in the amount of exposure the
person receives.

The Occupational Safety and Health Administration (OSHA) has developed
occupational radiation standards. Those can be found in regulations at
29 CFR 1910.1096. These apply whenever an operator becomes aware of the
presence of radiation at the facility, that's the trigger. Although
these standards may not apply to municipal water treatment plant
workers, these workers may be covered by the state OSHA programs
requiring that all controls, monitoring, record keeping, and training
outlined in the OSHA standards be met.

OSHA standards that may be applicable to water systems include
requirements that personal protection equipment (PPE) for the eyes,
face, head, and extremities, such as protective clothing, respiratory
devices, and protective shields and barriers be provided, used, and
maintained whenever processes or radiological hazards capable of causing
injury for absorption, inhalation, or physical contact necessitates such
equipment. There are numerous other requirements related to the
possession and use of PPE, including training for employees who would
use the equipment. This can be found in the regulations at 29 CFR and
1910 Sections 132-136. Requirements for practices and procedures to
protect employees in general industry from the hazards of entry into
permit-required confined spaces and needs to be set up as well and
there's special discussions about that in 29 CFR 1910.146.

In addition to the OSHA requirements, systems should be encouraged to
follow the safety practices described next. These measures can reduce
workers at risk of exposure to radioactivity and radioactive
particulates. Use an OSHA approved respirator to avoid inhalation of
biological pathogens and chemically toxic materials and residuals.
Simple dust masks may not provide adequate protection. Limit time spent
at land disposal sites, ventilate all buildings, especially where waste
with high concentrations of radium is stored and take standard OSHA
measures to limit potential ingestion of heavy metals and biological
pathogens present in filters, sludges, and then all disposal sites to
reduce possible ingestion and exposure to radioactive materials.

Use protective gloves and frequently wash hands to reduce the potential
for ingestion. Similarly, avoid eating and drinking in the vicinity of
facilities or land disposal sites. Locate treatment units and waste
storage area as far away from common areas such as office as possible.
And shower after exposure to potentially radioactive materials. Also,
launder work clothing at the system if possible.

If laundering equipment is not available, workers should keep and wash
work clothing separately and avoid wearing contaminated clothing into
the home. Work boots and shoes should be wiped and cleaned after
potential contamination. They should stay at the system or not be worn
into the home. Use gamma survey instruments or monitors at least once
annually to monitor the system's ambient radiation levels in areas where
radionuclides are removed.

Monitor levels of radiation to which staff are exposed. Systems should
contact or be referred to state or other radiation experts for more
information on how to monitor radiation levels. If radionuclides or
radiation had been found in drinking water or at a system, having
operators who are trained in treating for radionuclides, handling,
disposing of, and transporting waste is highly recommended. Operators
should also be trained in how to measure radioactivity levels. Systems
should check with their state to determine whether classes are
available.

Radon is a natural decay product of radium and other radium nuclides.
It's therefore appropriate for systems to consider radon protection
measures when handling waste containing radon. EPA recommends that water
systems should check for the presence of radon in buildings and casing
system equipment and that action should be taken to reduce radon levels
where testing shows average concentrations of 4 picocuries per liter or
greater.

OK. And here's some information, who to contact, assistance and advice
are available from appropriate state radiation control programs, the
Conference of Radiation Control Program Directors (crw.crcpd.org), and
the EPA Regional Radiation Programs and we have a contact at the EPA
Radiation TENORM site. It's called keyradcontacts.htm. OK. And that's
it.

**Andrea:** Great, thanks, Loren. Looks like we had a question that came
in. "Do we have any evidence that exposures are significant at water
treatment plants?"

**Loren:** Well, at this point, we don't, but we do know that the levels
of radiation associated with, particularly some of the resin filters,
are extremely high. We've seen numbers as high as 40,000 picocuries per
gram for radium. Those kind of exposure levels for any prolonged period
might be potentially harmful and so it's going to be up to the systems
once they know that they have radiation potential issues and
accumulations to begin to do a survey to determine if they may have
possible problems.

**Andrea:** Thank you. Looks like we have about eight minutes or so for
questions. There were a few questions that came in from Nebraska on
point-of-use and the first one, "does the EPA know of any point-of-use
devices that are certified for the removal of uranium?" The last time I
checked that, I was unable to find any point-of-use devices that had
been certified by NSF or NIST for the removal of uranium. And that's
true right now. There aren't any NSF standards right now for
point-of-use for uranium and that is something that our staff is looking
at to see if that's something that we could push NSF a little bit more
in trying to get a standard for uranium for point-of-use. Another
question was, "what frequency of testing, both initial and routine is
recommended for point-of-use devices?" That's something we have a draft
guidance document right now for point-of-use and in there, it doesn't go
into that much detail either in terms of the frequency of testing. I
know we get a lot of questions about that, if you're going to use
point-of-use, how frequent should you be testing your waters, sampling
your waters? And that's something right now that may be left up to the
state, but there are definitely questions about that and in terms of the
implementation guidance right now, it's out for review and they're
hoping to have it finalized sometime this fall.

Another question that came from that is, "what is the maximum number of
connections for a point-of-use device to be economically feasible?" And
that, again, kind of depends really on the technology that you're going
to be using, but probably on average, maybe 20-100 households. We find
it economically feasible and part of it is just going over 100 people,
is that costs are increasing with the maintenance of the point-of-use
devices, so that's kind of where your costs are going up. I think that's
it. Are there any other questions? I know we had some questions in terms
of treatment technologies. Dennis, were you able to see any of those
during the Web cast?

I think there was a UIC question that said, "what is the definition of
hazardous or radioactive?"

**Bruce:** This is Bruce. I was able to just jump out and do a little
bit of research. There were actually two questions. One was, "how do PWS
systems overcome the high cost of Class I wells?" That's actually a good
question. I mean typically these Class I wells can cost upwards of a
million dollars and so I don't want to scare anyone away from it, but
yeah the cost of permitting and construction is pretty high. I think one
thing that we should make it clear is that you just can't go to any
Class I well. Pretty much you have to go to a Class I well that's a
commercial facility that's willing to take these type of waste streams
and just don't go looking to like a neighboring facility and expect that
they will take that waste either.

Someone also asked the question, "what do you use for determining
whether it's hazardous or radioactive?" Well, as far as the hazardous
question goes, we're no different from RCRA. You can go to your 40 CFR,
Part 261 and look at what the levels are. For example, if it fails TCLP,
what are the levels that will make it a toxic waste and, therefore, a
hazardous waste, they're listed in there. For example, arsenic 5 mg per
liter. Also, if it's an ignitable waste or it's a corrosive waste if
your pH is less than 2 or greater than 12.5, that may cause it to be a
hazardous waste and if it's a reactive waste, I don't know what the
characteristics are of these drinking water residuals. If whether or not
they're ignitable or reactive, but that could make it a hazardous waste
as well and I think we've put down the information about what we
consider in the UIC program makes it a radioactive waste, so I just
won't go into that anymore.

**Dennis:** Andrea, this is Dennis. I tried to answer that question, but
my microphone was muted and pushed the off button and had to get
reconnected. There was one question that said "about barium sulfate, why
is this not used?" I really don't know of any. I spent some time
visiting a plant in Saudi Arabia that has a barium sulfate system and
they actually preferred it for radium removal to manganese oxides
because the manganese oxides were black and they were showing up
everywhere in the plant. One of the issues that came up just a few
minutes ago was radiation safety. One of these precipitating things like
manganese and barium will make a pipe scale and that pipe scale will
generate a lot of alpha activity due to the radium, lead 210, and
there's some gamma activity that comes off and through the pipe and so
that may be one reason barium sulfate is not used, but I don't know any
reason, not costwise, I think its cost is reasonable, and the fact that
it's a white precipitate rather than a black scale, that would stain
fixtures and things in the system is probably an advantage.

Another question was, "do we have arsenic and uranium removal problems
together, as co-contaminants?" I don't, never have worked with any
directly, but ion exchange will work. If you're removing arsenic, you're
also removing uranium and when you regenerate the resin, you will
regenerate the uranium off, so it's not a problem. If there's arsenic in
the water, arsenic can be removed by ion exchange and uranium will be
removed at the same time. The issue that I did run across is perchlorate
contamination with uranium and in that case, the perchlorate runs for a
very long time in those situations, they may run for a hundred or tens
of thousands of bed volumes and, in that case the uranium that builds up
on the resin may be a problem. In fact, it's been suggested that those
columns be regenerated just to remove the uranium and while not actually
removing much of the perchlorate. Those are the only questions that I
remember seeing.

**Andrea:** Great, thanks Dennis. We do definitely have some other
questions out there, it looks like we're just about out of time here,
so, as I said before, we'll do it like we did for the last Web cast.
We'll have a question and answer log that we will answer and post onto
our web site. Again, it's going to take some time, there's a lot of good
questions out there and it takes some time for us to answer, so we
really do appreciate your patience in waiting for these questions and
answers to come out. We are also sending out another evaluation as we
did for the last ones. We really encourage you to fill it out, it really
helps us in developing our next Web casts that are coming down and
speaking of Web casts, we do have our next two arsenic Web casts and
they're scheduled for September 15^th^ and October 20^th^. So, I hope
you can all make it and also we're having some total coliform rule Web
casts coming up as well, so stay tuned for those. So, with that, thank
you again for participating in this Web cast. We really appreciate it
and hope you got something out of it. So, I think we're finished and
thank you again.

**Host:** That concludes today's seminar and thank you for joining us
today. The slides shown in today's presentation will be posted on the
EPA's website in the very near future. Have a great day.

\* \* \*