Source Type System Type Population Type















Surface Water < 10,000

Ground Water 10,000 - 100,000

GWUDI > 100,000

CWSs

NTNCWSs

TNCWSs

CRITICAL RULE DEADLINES & REQUIREMENTS

Using DWSRF Funds to Comply with

the Radionuclides Rule

The Drinking Water State Revolving Fund (DWSRF) program was established by the 1996 Safe Drinking Water Act (SDWA)

Amendments and authorizes grants to states to capitalize revolving loan funds. The states provide low-interest loans to eligible

systems for infrastructure improvements needed to ensure compliance with the SDWA and protect public health. The

DWSRF program can play a significant role in helping systems, especially small systems, to meet the challenges of complying

with new drinking water standards.

The Environmental Protection Agency (EPA) published revisions to the Radionuclides Rule on December 7, 2000 which

further protect the public from exposure to radioactive substances in drinking water. The revisions include a new uranium

maximum contaminant level (MCL) of 30 ppb and a requirement to monitor separately for radium-226 and radium-228,

resulting in an increased number of systems out of compliance with the combined radium MCL. These changes will impose a

financial burden on some water systems. The DWSRF can provide assistance to systems to help ease this burden, increase

compliance, and protect public health.

WHY DID EPA CREATE THIS RULE?

EPA began regulating radionuclides in 1976 by establishing MCLs under the SDWA. In the quarter century since, EPA has

learned more about the potential health effects from consuming water with high concentrations of radionuclides. The new

uranium MCL of 30 ppb will provide additional protection for 620,000 people and decrease the incidence of cancers and

kidney problems. Due to the mistaken conclusion that systems with low levels of radium-226 would also have low levels of

radium-228, the current standards only required analysis of radium-228 when levels of radium-226 exceeded 3 pCi/L. Based

on a better understanding of radium-228 incidence, EPA closed this loophole by requiring separate monitoring for radium228. This change will reduce radium exposure for 420,000 people and reduce the incidence of cancer.

TO WHOM DOES THIS RULE APPLY?

The Radionuclides Rule applies to all community

water systems (CWSs). Of all affected systems,

98% are small systems that serve fewer than 10,000

people. Higher levels of radionuclides tend to be

found in ground water rather than surface water

sources (i.e., lakes and rivers). Compared to the

rest of the United States, western states and states

in the Great Lakes region tend to have higher

occurrence of radionuclides in ground water.

FOR SYSTEMS* FOR STATES

States began updating vulnerability assessments for beta photon and particle emitters and notifying systems of

monitoring requirements. December 8, 2000

EPA explained new rules and requirements to states. Spring 2001

Deadline for states to submit primacy revision application to EPA. December 8, 2002

December 8, 2003 New MCL and monitoring requirements take effect. Systems must begin initial monitoring. When allowed by

the state, systems may be permitted to grandfather data collected before this date and June 2000.

December 31, 2007 Initial monitoring must be completed.

*Deadlines for a specific system may be affected by variances or exemptions granted by the State.
Figure 1: TOTAL RADIONUCLIDES

RULE PRICE TAG (in millions of 1999 $)

Capital Costs

Capital Costs

by System Size

< 100

101-500

$4

$14

$11

$29

$215

$131

$31

$3

$346 $38

$108

$142

501-1,000

1,001-3,300

3,301-10,000

>100,000

10,001-100,000

Uranium MCL

Closing Radium-228 Loophole

CAPITAL COST GRAND TOTAL

Annual O & M Costs

Annual Monitoring Costs

Figure 3: Number of CWSs Affected by the

Radionuclides Rule

Figure 4: Average Annual Compliance Cost per CWS

Exceeding Uranium or Combined Radium MCL

(in thousands of 1999 $)

Note: Costs based on total costs amortized over 20 years at a 3% discount rate.

HOW WILL THIS RULE IMPACT SYSTEMS?

The costs systems will face to meet the new Radionuclides Rule

are significant. Systems will incur capital costs for two requirements under the rule:

• Compliance with the new uranium MCL of 30 μg/L; and

• Closing the combined radium monitoring loophole by

requiring separate monitoring for radium-228.

The total capital costs for investments in treatment technology

and infrastructure to meet these provisions are estimated to be

almost $350 million (see Figure 1). In addition, annual operation and maintenance (O & M) and monitoring costs for

systems will top $34 million. As shown in Figure 2, most of the affected CWSs are ground water systems (radium is normally

not present in appreciable levels in surface water).

Approximately 53,156 CWSs are subject to the provisions of the Radionuclides

Rule, less than 1,000 of which will have to install treatment. EPA estimates that

98% of the systems that will need to take action to come into compliance with

the uranium or combined radium MCLs serve less than 10,000 people. Therefore, most of the capital costs created by the rule will fall on the shoulders of small

water systems (see Figure 3). Most of these systems will have to take action to

comply with the new uranium MCL.

Figure 4 illustrates how much it will cost systems (on average) to meet the new

standards. Systems that would be out of compliance with the new uranium MCL

may have to install new technologies, upgrade existing technologies, consolidate

into larger systems, or develop new water sources. The requirement to monitor

separately for radium-228 and radium-226 will result in more systems facing non-compliance with the combined radium

MCL, creating infrastructure needs and annual compliance costs similar to those for the uranium MCL. With the closing of

the radium monitoring loophole, approximately 270 to 320 systems currently in compliance with the combined radium MCL

due to assumed low levels of radium-228 will now have to take action to retain their compliance status.

The average increase in costs per household to meet the new uranium MCL and the new radium monitoring requirements

depends on the size of the water systems and how many people are served by that system. The estimated compliance cost per

system is considerably lower for small systems than for large systems because less water must be treated. However, the burden

on small system households is significantly higher because the costs must be paid from a much smaller revenue base. EPA

estimates that the average annual household water bill for ground water systems out of compliance may increase by $18-$180

for the uranium MCL and $8-$126 for the combined radium MCL. The uranium compliance costs will be significantly

cheaper for surface water systems ($3-$72 per household).

Figure 2: Percent of Systems Affected

by the Radionuclides Rule

1.3%

0.7%

0.2%

0.0%

0.5%

1.0%

1.5%

2.0%

Ground Water Surface Water

Radium

Uranium

0

50

100

150

200

250

300

350

25-100 101-

500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001-

100,000

Population Served

Radium

Uranium

$0

$500

$1,000

$1,500

$2,000

25-100 101-

500

501-

1,000

1,001-

3,300

3,301-

10,000

10,001-

100,000

Population Served

Radium

Uranium
WHAT TYPE OF TREATMENT WILL SYSTEMS HAVE TO PUT IN PLACE?

There are many available technologies capable of removing

radionuclides. These treatment options differ greatly in terms

of capital and O & M costs and operator skill required for

proper operation. The characteristics of a system’s source

water, the skill level of its operators, and other compliance

considerations will greatly impact which treatment train is

most appropriate as well as the ultimate cost of compliance.

Systems with treatment trains in place that can remove radionuclides will face lower compliance costs than those without

pre-existing treatment capability. For instance, most surface

water systems already have treatment in place (coagulation or

filtration) that, if enhanced, is capable of removing uranium.

The rule lists several Best Available Technologies (BATs) for

the removal of radionuclides (see Exhibit 1). In addition, the

rule lists Small System Compliance Technologies (SSCTs),

which are specifically recommended for use by small systems

serving fewer than 10,000 people. When considering SSCTs, EPA looks at the affordability of the technology (since per

household costs for central treatment tend to be higher for

smaller system customers) and technical complexity (since many

small systems do not have access to well-trained water system

operators). The SSCTs represent technologies that are affordable

and achieve compliance across the small system size categories

(25-500; 501-3,300; and 3,301-10,000 people). For example,

reverse osmosis and ion exchange/activated alumina point-of-use

(POU) devices are viable options for small systems, especially

those serving fewer than 200 people. Both BAT and SSCT

treatment technologies must be operated in very different modes

depending on which radionuclide is being removed.

Figure 5 illustrates the estimated CWS compliance strategies for

uranium removal. Despite operating difficulty, most systems are

expected to install lime softening capability. Approximately 17%

of CWSs are expected to develop an alternative water source,

while an equal number will comply through regionalization or

water blending. About 10% of small water systems are expected to elect to comply by installing either ion exchange, activated

alumina, or reverse osmosis POU devices. Technology

choices for radium removal are expected to mirror those for

uranium removal, except that up to 20% of CWSs will

choose greensand filtration over lime softening.

To ensure cost-effective compliance with the uranium and

combined radium MCLs, systems will need to evaluate their

treatment technology options as a first step. All other factors

being equal, systems will most likely choose the cheapest

treatment option that ensures compliance. Figure 6 illustrates estimated cost ranges for an average CWS serving

between 25 and 500 people that operates the technology at

30% removal efficiency. The costs are production costs per

1,000 gallons treated for both surface and ground water

systems removing either radium or uranium. These estimates include costs associated with residuals handling and

disposal.

Figure 5: Percent of CWSs Using Various Treatment

Technologies and Strategies for Uranium Removal

0%

20%

40%

60%

80%

100%

25-500 persons 501-1,000,000 persons

Population Served

1 2 3 6

Figure 6: Representative Production Costs for CWSs

Serving Populations of 25-500 (in 1999 $ per 1,000

gallons treated)

$0

$1

$2

$3

$4

$5

$6

1 2/3 4 5

Treatment Technologies

= High Estimate

= Low Estimate

Exhibit 1: Radionuclide Treatment Technologies & Strategies*

Treatment Technology or

Strategy

FOR... POU

Uranium Option Combined

Radium

Surface

Water?

1 * Lime Softening* T Y Y T YES

2 Ion Exchange/

Activated Alumina T Y Y T YES

3 s Reverse Osmosi T Y Y T YES

4 Enhanced Coagulation/

Filtration*** T Y YES

5 n Greensand Filtratio Y

6 . Other, including source change, regionalization, and blending

T = Best Available Technology

Y = Small System Compliance Technology

*Referenced in Figures 5 and 6.

**Central treatment is only uranium SSCT for systems >500.

***Assumes that a system already has coagulation/filtration in place.
Printed on Recycled Paper

FOR MORE INFORMATION...

DWSRF and Radionuclides Rule General Information

DWSRF Website:

http://www.epa.gov/safewater/dwsrf.html

Radionuclides Implementation Website:

http://www.epa.gov/safewater/rads/implement.html

SDWA Hotline

1-800-426-4791

EPA's Ground Water & Drinking

Water Website:

http://www.epa.gov/safewater/

Office of Ground Water and

Drinking Water (4606M)

EPA 816-F-02-008

May 2002

HOW CAN THE DWSRF ASSIST SYSTEMS?

States use DWSRF capitalization grant monies to provide low-interest

loans to publicly- and privately-owned public water systems for

infrastructure improvements needed to continue to ensure safe

drinking water. States may offer principal forgiveness, reduced

interest rates, or extended loan terms to systems identified by the state

as serving disadvantaged communities. States also have the ability to

reserve a portion of their grants (i.e., set-asides) to finance activities

that encourage enhanced water system management and help to

prevent contamination problems through source water protection

measures. Based on the fiscal year 2002 appropriation of $850

million, capitalization grants ranged from $8.0 million to $82.4

million per state. Where funding is not adequate for all systems that

require treatment, states may choose to offer extended compliance

schedules through exemptions, where appropriate, to some systems.

Most capital projects – including adding new technologies and

upgrading existing technologies – needed to comply with the Radionuclides Rule are eligible for funding under the DWSRF (see Exhibit

2). Consolidation and restructuring of systems can be a cost-effective

option for small systems that are affected by the rule. The DWSRF

can fund consolidation, including situations where a system is unable

to maintain compliance for technical, financial, or managerial reasons.

POU devices will be an attractive option to small systems because of

cost. The DWSRF can

fund these devices as long

as the units are owned and

maintained by the water

system.

States can use set-aside funds from the DWSRF to assist systems directly as well as

to enhance their own program management activities (see Exhibit 2). A state may

use set-asides to make administrative improvements to the entire drinking water

program, which faces increased costs in implementing the Radionuclides Rule.

States can provide training to small systems on meeting the requirements of the

rule as well as technical assistance in identifying appropriate technologies. In

addition, states can provide assistance to small systems to cover the costs of project

planning and design for infrastructure improvements.

Since the DWSRF program is managed by states, project and set-aside funding

varies according to the priorities, policies, and laws within each state. Given that

each state administers its own program differently, the first step in seeking assistance is to contact the state DWSRF representative which can be found on the

EPA DWSRF website.

Jackson, Nebraska

The Village of Jackson is a small

economically disadvantaged community

of 230 people in northeast Nebraska.

To achieve compliance with regulations

for radium-226, radium-228, and Gross

Alpha Particle Activity, the ground

water system in Jackson developed a

$500,000 project to install a new well

in a different aquifer, build a water

treatment plant for iron removal, and

make needed improvements to its

distribution system. The system

received a Community Development

Block Grant of $250,000 and a

$250,000 DWSRF loan with $125,000

in principal forgiveness. With this

assistance, Jackson was able to afford

the project and complete it in the

spring of 2000.

Exhibit 2: Projects/Activities Eligible for DWSRF

Funding to Comply with the Radionuclides Rule

Type of Project/Activity

Eligible Under

Infrastructure Fund

Eligible Under

Set-Asides

Treatment

W s ater Softening/Iron Removal Y o e N

I s on Exchange Y o e N

R s everse Osmosis Y o e N

E s nhanced Coagulation/Filtration Y o e N

G s reensand Filtration Y o e N

P * OU Devices Y o es N

P s lanning & Design Activities Y * e Yes*

System Consolidation Y o es N

System Restructuring Y s es Ye

System Administrative Improvements

H o ire Staff N oN

S o taff Training N s Ye

P o ublic Outreach N s Ye

M o onitoring N oN

R o ate Increase Process N s Ye

State Administrative Improvements

H o ire Staff N s Ye

S o taff Training N s Ye

P o ublic Outreach N s Ye

C o ompliance Oversight N s Ye

E o nforcement N s Ye

P o ilot Studies N s Ye

*Must be owned and maintained by system.

**For small systems only.