# Presentation: 214575

## Disposal of Water Treatment Plant Waste Containing Radionuclides

**Notes:**
Treatment processes remove contaminants from drinking water in order to meet drinking water standards expressed as MCLs or Treatment Techniques
Treatment processes will concentrate contaminants into solid or liquid waste streams that require appropriate handling and disposal

## Options for Disposal are Influenced by. . .  

- Concentration of radionuclides and co-occurring contaminants in the waste stream
- Hazardous Waste
- Technologically Enhanced Naturally Occurring Radioactive Material (TENORM)
- Low-Level Radioactive Waste (LLRW)
- Mixed Waste
- Federal, State, & Local Regulations
- Disposal facility policies
- Type of residuals
- Liquid or solid

**Notes:**
The options that you may have for disposal of water treatment waste streams are influenced by:
Whether co-occurring contaminants make the waste Hazardous
Whether the waste is considered a LLRW
The nature of regulatory controls on disposal facilities
Whether the waste is in liquid or a solid form

## Definitions for Waste

- Hazardous Waste
- Technologically Enhanced Naturally Occurring Radioactive Material (TENORM)
- Low-Level Radioactive Waste (LLRW)
- Mixed Waste

**Notes:**
In this next section, we’ll discuss some of the regulatory implications of each of the waste types you see on this slide
What you’ll see, is that each type of waste will exhibit a statutory framework that is likely to apply to a narrow category of waste, and what is defined for regulation under one statute is often exempted from another,..there is a good possibility that treatment processes can be operated so that they do not produce a waste that requires expensive or unique disposal,..but clearly the stakes are high, particularly with the hazardous designation,  and so the best course is an organized, sequential examination of the characteristics of your waste to determine inclusion and exclusion under the various statutes that must be considered when dealing with water treatment plant waste streams that may contain radionuclides..the last two slides in this series describe this decision-making process.. 

## Hazardous Waste

- Regulated under RCRA
- Hazardous waste is solid waste:
- Not excluded from regulation under 40 CFR 261.4(b)
- Exhibits toxicity, corrosivity, reactivity, or ignitability criteria listed under 40 CFR 261.3(a)(2) and (b)
- Presence of radionuclides does not *ITSELF* make the waste hazardous

**Notes:**
Solid waste is any garbage, refuse, sludge from a water supply treatment plant and other discarded material, including solid, liquid, semisolid, or contained gaseous material
Source, special nuclear or by-product material defined by Atomic Energy Act is among the specific exclusions listed in 40 CFR 261.4
So, you see that determining that a waste contains radionuclides does not make it hazardous under the RCRA

## TENORM

**TENORM**

- Regulated by numerous federal regulations
- Defined as naturally occurring materials whose radionuclide concentrations or potential for exposure is enhanced as a result of human activities
- Includes waste streams generated by water treatment plants
- Also includes mining, fertilizer production, and oil and gas production.

**Notes:**
Technically Enhanced Naturally Occurring Radioactive Material
This is a description, more than a legally defined, regulated substance or group of substances
We know that waste streams generated by water treatment plants contain TENORM, if there are radionuclides in the source water
Containing TENORM doesn’t guarantee regulation,..but does dictate that the waste be examined for content so that disposal is appropriately accomplished 

## LLRW

- Defined by The Low-Level Radioactive Waste Policy Act
- Not high level radioactive waste, spent nuclear fuel, or byproduct material; and,
- The Nuclear Regulatory Commission (NRC)...classifies as LLRW

**Notes:**
Defined in part, by what it’s not,..it’s not a high level radioactive waste, spent nuclear fuel, or byproduct material
It is classified by NRC as LLRW

## LLRW

- Can contain source or special nuclear material
- Radium (Ra) is not source or byproduct material by definition
- Uranium (U) & thorium (Th) are source material and may be subject to NRC licensing requirements

**HOWEVER. . . **

**Notes:**
A waste containing radium will not be a LLRW because Radium is not a source or byproduct material
A waste containing Uranium and / or Thorium, because they are considered source material, may be a LLRW, and may be subject to NRC licensing, however, there are some conditions.. 

## LLRW: Uranium & Thorium

- If U or Th makes up <0.05% by weight (totaling less than 15 lbs.), it is source material an “unimportant quantity” and exempt from NRC Regulations
- Approximately 335 pCi/g for natural U

**Notes:**
A few beta/photon emitters occur naturally and can be present in source water; others remain as a legacy of fallout from nuclear weapons testing.  
Check with the state Radiation Program to see if beta/photon emitters are considered byproduct material.
  In order for uranium or thorium content to trigger the determination for NRC licensing, the waste must contain 0.05% or more uranium or thorium by weight
If the waste contains less than 1/20th of one percent (0.05%) uranium or thorium by weight, it is determined to be an unimportant quantity, and is exempt from NRC licensing (this can also be expressed as about 335 pCi/g for natural uranium
In addition, NRC issues a general license for source materials of not more than 15 pounds at a time or 150 pounds per calendar year (this is a small quantity of source material)–over 15 pounds at a time or over 150 pounds per year may require a specific license from NRC

## Mixed Waste

- Regulated under RCRA and the Atomic Energy Act (AEA)
- Contains both hazardous waste and source. . . or byproduct material subject to the AEA

## Statutes and Regulations

| RCRA | CWA |
| --- | --- |
| SDWA | DOT |
| AEA/NRC | State Requirements |

**Statutes and Regulations**

**Notes:**
In this section we’ll talk about the Laws and Regulations that may govern handling and disposal of radioactive wastes

## Things to Consider

- Numerous federal regulations
- No federal waste disposal regulation specifically for TENORM
- Key definitions vary among regulations
- States, locality, and waste disposal facility may have additional requirements

## RCRA 42 USC 6901 et. seq.

- The identification, management, and disposal of solid wastes (including sludge)
- If you generate solid waste, you must determine whether the waste is hazardous
- Use a method described in 40 CFR 262.11

**Notes:**
Water systems are required to determine whether the waste they generate is hazardous.  
This may be done using knowledge of the waste generation process, analytical testing, or a combination of both.  
Analytical testing uses leachate tests such as the Toxicity Characteristic Leaching Procedure (TCLP) (Method 1311, as described in EPA publication SW-846, “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods”), which applies to 40 substances, including metals, pesticides, and other organic compounds.  
 If the waste is hazardous, it must be managed under RCRA Subtitle C requirements.

## RCRA: Hazardous Waste

- Solid waste exhibiting toxicity, corrosivity, reactivity, or ignitability characteristics is hazardous
- Requirements depend on the amount of hazardous waste produced monthly and the amount of hazardous waste stored on site at any given time
- Large Quantity, Small Quantity, or Conditionally Exempt Small Quantity
- “Cradle to Grave” liability

## RCRA

- RCRA Subtitle C requirements apply to hazardous waste disposal
- Hazardous Waste Landfill
- LLRW Landfill

- RCRA Subtitle D requirements apply to non-hazardous waste solid waste disposal
- Municipal Solid Waste Landfill (MSWLFs) requirements
- Some MSWLFs can accept commercial solid waste, nonhazardous sludge, CESQG waste, and industrial nonhazardous solid waste
- Hazardous Waste Landfill
- LLRW Landfill

**Notes:**
Minimum national criteria for MSWLFs is included at 40 CFR 258 (Subtitle D of RCRA)
Location, operation, and design; ground water monitoring; corrective action; closure and post-closure, and financial assurance
MSWLF is a discrete area of land or excavation that receives household waste  

## Clean Water Act (CWA) 33 USC 1251 to 1387

- Direct discharges under a National Pollutant Discharge Elimination System (NPDES) permit
- Discharges to a publicly owned treatment works (POTW)
- Federal NPDES regulations do not set specific limits on radionuclides in discharges
- EPA regulations on the use and disposal of the sewage sludge produced by POTWs currently do not cover radioactive material

## CWA

- Systems should:
- Contact the state NPDES program to determine if the system needs an NPDES or other permit
- Contact the state NPDES program to determine if the system is capable of meeting the applicable local limits
- Contact their POTWs to ensure that the wastes will be accepted

## SDWA 42 USC 300f et seq.

- EPA required to develop minimum requirements for underground injection control (UIC) programs
- Stay tuned. . .

## DOT Regulations 49 CFR 171 to 180

- Govern shipping, labeling, and transport of hazardous materials
- DOT definition of hazardous includes radioactive materials

**HOWEVER. . . **

## DOT: Exemptions

- DOT exempts, “other natural materials or ores... when these have been subjected to physical or chemical processing, when the processing was not for the purpose of extracting radionuclides...provided that their radionuclide concentration does not exceed 10 times the activity concentration in the table in 49 CFR 173.436.”

- For example
- Uranium is listed in the table in 49 CFR 173.436 at 27 pCi/g
- Radium-226 and -228 are listed at 270 pCi/g
- Therefore, a system would need to transport over 270 pCi/g of uranium or 2,700 pCi/g of radium before meeting the “10 times” exemption threshold

## AEA42 USC Chapter 23

- AEA regulates the development and use of nuclear facilities, and the creation, generation, and disposal of source, special nuclear, and byproduct material
- Uranium and thorium are source material
- NRC has exempted some source material
- Uranium or thorium makes up <0.05% by weight

## State TENORM Regulations

- Currently regulated by 13 states
- http://www.tenorm.com/regs2.htm#States

## Residual Type

- Solid Residuals
- Liquid Residuals

## Waste Streams

- Liquid Residual Stream
- Brine
- Backwash Water
- Rinse Water
- Acid Neutralization Water
- Concentrate

- Solids
- Spent Resins
- Spent Filter Media
- Spent Membranes
- Sludges

**Notes:**
Brine waste typically contains high concentrations of radium, uranium, and other inorganics.

Probably use cartridges for IX on POU- cheaper than regenerating.  Disposal of cartridge could be an issue due to high concentration of radionuclides

## Solid Residuals by Treatment Type

| Treatment | Spent Resins/
Media | Spent 
Membranes | Sludge |
| --- | --- | --- | --- |
| IX | X |  |  |
| RO |  | X |  |
| AA | X |  |  |
| Coagulation/Filtration | X |  | X |
| Lime Softening | X |  | X |
| Green Sand Filtration | X |  | X |
| Co-Precipitation w/Barium Sulfate | X |  | X |
| Electrodialysis/Reversal |  | X |  |
| Pre-formed Hydrous Manganese Oxide Filtration | X |  | X |

## Liquid Residuals by Treatment Type

| Treatment | Brine | Backwash | Rinse Water | Acid Neutral Water | Concentrate |
| --- | --- | --- | --- | --- | --- |
| IX | X | X | X |  |  |
| RO |  |  |  |  | X |
| AA |  | X | X | X |  |
| Coagulation/Filtration |  | X |  |  |  |
| Lime Softening |  | X |  |  |  |
| Green Sand Filtration |  | X |  |  |  |
| Co-Precipitation w/Barium Sulfate |  | X |  |  |  |
| Electrodialysis/Reversal |  |  |  |  | X |
| Pre-formed Hydrous Manganese Oxide Filtration |  | X |  |  |  |

## Disposal Options

- Direct Discharge
- Discharge to POTW
- Underground Injection
- Landfill

## Disposal Options

| Residual Waste | Disposal Options |  |  |  |  |
| --- | --- | --- | --- | --- | --- |
|  | Direct Discharge | Discharge to POTW | Recycle | Underground Injection | Landfill |
| Liquids | X | X | X | X |  |
| Sludge |  |  |  |  | X |
| Spent Media |  |  |  |  | X |
| Spent Membranes |  |  |  |  | X |

## Other Options?

- Incineration
- Evaporation ponds
- Surface impoundments
- Sludge dewatering

- Intermediate processing methods each creating its own residual stream

- Not encouraged unless there is a demonstrated benefit and the benefits are weighed against potential hazards & risks

- Landspreading or soil mixing

**Notes:**
For some systems, processing residuals prior to disposal may be cost-effective.  The available intermediate processing options vary in complexity and may help determine the final disposal method.  Residual processing may be as simple as collecting residuals for direct disposal or as difficult as incorporating complex treatment technologies that generate additional residual streams which must also be addressed.  
Intermediate processing can make residual streams eligible for disposal via the sometimes otherwise limited methods available to a system and, in some cases, can reduce the volume of waste produced.
EPA is aware that some states allow landspreading or soil mixing as an alternative to landfill disposal for water treatment residuals (for example, as a soil amendment on farm fields).  
EPA does not encourage the landspreading or soil mixing of such TENORM unless there is a demonstrated benefit to the public from the material involved.  
Where benefits from land application are construed to exist, EPA believes that such benefits should be weighed against potential hazards and risks of the practice.  
One central concern is the potential for build-up or movement of radionuclides to create contaminated sites that would require remediation and/or use of institutional and engineering controls.  Other factors to take into account include the physical and chemical attributes of the material, the amount of radiation introduced into the soil over time, the mobility of radionuclides and their decay products along multiple pathways of exposure, and the consideration of future controls and future land use.  
Programs would need to be designed to provide adequate risk protection to human health and the environment." 

## Liquids: Direct Discharge

- CWA
- Need accessible and appropriate receiving body
- Must have a National Pollutant Discharge Elimination System (NPDES) permit

- Federal NPDES regulations do not set specific limits on radionuclides in discharges but:
- State anti-degradation policies
- Source water protection policies
- Co-occurring contaminant limits set in NPDES

- May limit the use of this disposal option

**Notes:**
Direct discharge may be an option for disposal of liquid wastes if a system has an accessible and appropriate receiving body.  The CWA requires that anybody discharging pollutants into U.S. waters through a point source, obtain a National Pollutant Discharge Elimination System (NPDES) permit from the state or EPA Region (CWA, Title IV, Section 402).  These permits set limits on the amount of certain pollutants that can be discharged.  They also set monitoring and reporting requirements, and they may include other provisions that protect water quality and public health.  

Federal NPDES regulations do not set specific limits on radionuclides in discharges.  States have the authority to establish these limits, and state anti-degradation policies designed to protect the quality of certain water bodies and source water protection efforts might restrict the levels of radionuclides in discharged waste.  The BATs and SSCTs designated for radionuclide removal also remove co-occurring contaminants for which NPDES regulations set limits, further restricting a system’s options.

## Liquids: POTW

- Discharges to a POTW
- POTW will have NPDES permit
- System may need local permit or contract
- Both the system and the POTW are responsible for:
- Preventing the introduction of any pollutants that may interfere with the POTW treatment process, contaminate POTW sewage sludge, or violate POTWs NPDES permit
- Meeting technically based local limits (TBLLs)
- Meeting pretreatment regulations
- POTW owners can refuse to accept waste

## Solids: Landfill

- Determine if the waste is hazardous through knowledge of the waste generation process, analytical testing, or both
- Toxicity Characteristic Leaching Procedure (TCLP) (EPA Method 1311)
- Determine if waste contains any “free liquids”
- Perform the Paint Filter Liquids Test (or PFLT; EPA SW 846 Method 9095)
- Conduct intermediate processing to remove any liquids
- No federal requirement to test residuals specifically for radionuclides
- No specific federal regulation governing landfill disposal of water treatment plant solids or sludges containing TENORM

## Solid Waste Landfill

- Municipal solid waste landfills may accept:
- Non-hazardous, solid, TENORM wastes from all water systems
- Hazardous waste from Conditionally Exempt Small Quantity Generators
- Industrial solid waste landfills may also accept:
- Non-hazardous solid TENORM waste

## Hazardous Waste Landfill

- May accept hazardous waste from all generator classes
- Hazardous waste from Large and Small Quantity Generators must meet RCRA Land Disposal Restriction requirements (40 CFR 268.40)
- Some hazardous waste landfills have explicit permit conditions while others may have to request state approval before accepting TENORM wastes

## LLRW Landfills

- Licensed by NRC or by a state under agreement with NRC
- Barnwell - South Carolina
- After June 30, 2008, will accept waste only from organizations in South Carolina, Connecticut, and New Jersey
- Richland - Washington
- Accepts certain types of TENORM (although not hazardous or mixed) wastes from all states
- Envirocare - Utah
- Has dedicated TENORM disposal and is the only LLRW landfill authorized to accept certain kinds of mixed waste

## Slide 35

**Notes:**
*Check with the state Radiation Program to see if beta/photon emitters are considered byproduct material
**Check with the state Radiation Program to determine the proper disposal methods for waste containing redionuclides and hazardous waste

## Slide 36