I-D.2.3 Mixed Waste

Mixed waste is regulated under RCRA and the Atomic Energy Act (AEA) of 1954. Mixed waste “contains both
hazardous waste and source...ot byproduct material subject to the Atomic Energy Act of 1954” (42 USC 6903.41).
Therefore, although highly unlikely, systems generating waste containing uranium or thorium (source material) as well
as hazardous waste could potentially have a mixed waste. Lf wastes contain licensable amounts of source material (any
concentration exceeding the “unimportant quantity” in 10 CFR 40.13 (a) and hazardous waste, these wastes must be
disposed of at a facility authorized to accept mixed waste. Because there are limited disposal pathways, generation of a
mixed waste should be avoided if at all possible. For more information on licensing requirements and Agreement
States, see the discussion of the AEA in Appendix C.

If either portion of the waste is exempted or excluded under RCRA or the AEA (and the regulations promulgated
under these Acts), it is not mixed waste. A system generating hazardous waste does not have mixed waste if the
amount of source material generated 1s an “unimportant quantity” (uranium or thorium makes up less than 0.05
percent by weight of the matertal), or if the waste contains only radium (since radium is not considered source or
byproduct material when present in water treatment residuals).

Hazardous waste that contains beta/photon emitters could be considered mixed waste if a licensed source of the
contamination can be identified. 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 or originate from discharge from nuclear or medical
facilities. Check with the state Radiation Program to see if beta/photon emitters are considered byproduct material.
Note that because radium is not considered source or byproduct material, waste containing only radium would not
legally be defined as a mixed waste under federal regulations.

I-D.3 Possible Disposal Options if Elevated TENORM is Present

The majority of water treatment systems should not have problems with radiation. The following discussion is
intended as guidance for states on disposal options for systems that do have elevated levels of TENORM in their
treatment residuals. Table 5 summarizes disposal options for TENORM residuals, Each option is discussed in more
detail below.



II-B Intermediate Processing

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.

Table 17 outlines intermediate processing options, according to the type of residual produced.

‘Table 17: Intermediate Processing Options

Intermediate Treatment
Flow Chemical Precipitation/

Residual Stream Equalization pH Adjustment! Thickening! Dewatering” Recycle
Brine, Backwash, Rinse, v v v v v
and Acid Neutralization

Concentrate v v v v
(.e., membrane reject
stream)
Spent Filter Backwash and v v v v v
Filter-to-Waste
Sludge v v v

"Sludge and supernatant produced.
“Dewatering is preceded by thickening, Sludge of increased solids concentration and liquid from dewatering produced.

» Flow equalization is necessary when residual streams do not have a consistent flow and vary significantly in their
physical and chemical characteristics. These may include liquid wastes from IX and AA processes, spent filter
backwash, and filter-to-waste. Systems may need to collect the regeneration waste stream in a holding tank to
ensure constant flow and radionuclide concentrations. If the tank is mixed, then a sludge will not be produced. If
the tank is not mixed, a supernatant and sludge will be generated, and the system must decide how to dispose of
these wastes. :

> Chemical precipitation involves precipitation of ions into an insoluble form in a reactor vessel followed by
separation in a clarifier. (Flocculation can be used to enhance removal of suspended solids.) This procedure
generates two waste streams that must be disposed of: a supernatant and the precipitated waste slurry or sludge.
Systems may be able to recycle the supernatant. In addition, pH adjustment may be necessary for disposal of
residuals. Compliance with specific disposal options may require that acidic or basic liquid residuals be
neutralized.

» Thickening of liquid residuals, such as spent filter backwash, or sludge wiil allow the liquid and solids to separate.
This produces a sludge and supernatant that may require further processing. Depending on the treatment
technology used, both the sludge and the supernatant could contain radionuclides.

» Dewatering increases the solids concentration for final disposal, producing a sludge of increased solid
concentration and a liquid. This can be done mechanically (¢.g., through a centrifuge, belt filter press, or vacuum
filter), or non-mechanucally (¢.g., through sand drying beds, freeze-thaw beds, solar drying beds, or dewatering
lagoons). These non-mechanical processes may not be cost-effective; they are very land-intensive and can be

34


Table 10: Lime Softening Overview

BAT Listed BAT for the removal of radium and uranium from drinking water
Use SSCL Listed SSCT for the removal of radium for systems serving 25-10,000 customers and for the
removal of uranium for systems serving 501-10,000 customers
Removal efficiency depends on the pH of the influent water
Seventy-five to 90% of radium can be removed from water with pH levels above 10;7 the pH range for
radium removal is 9.5 to 11.0
Efficiency Uranium removal can be as low as 16% and as high as 97%;"* the pI should be at least 10.6
Adding magnesium carbonate during treatment can increase the efficiency of uranium removal to 99%;
ferric chloride may also increase efficiency, depending on raw water uranium concentrations and pH
See also Appendix E, Table E-1
Lignid Spent filter backwash water (contains radium, uranium, particulates, and co-occurring
contaminants)
Residuals
Solid Spent filter media and lime sludge (contains high concentrations of radium, uranium, and co-
occurring contaminants)
Additional Landfill Because of high concentrations of radionuclides and co-occurring contaminants, sludge may
Disposal disposal | require special disposal (.e., in a LLRW’ or hazardous waste landfill)
Issues*
Using lime softening technology necessitates having a highly skilled system operator
ye ‘There are many source water quality concerns that should be addressed to ensure the efficiency of
Limitations y ;

radionuclide removal and the process involves complex water chemistry. This technology may be too
complicated, expenstve, and time-consuming for small systems to use.

*All of the common disposal considerations in Table 7 must also be taken into account.

Table 11: Green Sand Filtration Overview

Use SSCT Listed as a SSCT for radium removal for systems serving 25-10,000 customers
Green sand has shown removal efficiencies ranging, from 19% to 63% for tadium-226 removal and 23%
to 82% for radium-228 removalTM
Effcion High concentrations of manganese in an oxidized state increase the efficiency of radium adsorption; high
of concentrations of manganese in an waoxidized state or iron in the ferric state limit the efficiency of
adsorption
See also Appendix K, Tables E-1, B-6, and E-7
Liquid Spent filter backwash water (contains radium, particulates, and co-occurring contaminants)
Residuals
Solid Spent filter media and sludge
Source water quality can greatly affect the efficiency of green sand filtration in removing radium from
a drinking water
Limitations 8

If the pH of the water is below 6.8, green sand may remove an inadequate level of iron and manganese;
running the water through a calcite filter or adding lime or sodium hydroxide can raise the pH above 7.0

“Brink, W.L., et al, 1978, U.S, EPA, 1977; Us

Sorg, T., 1990.

* Peterson, K., 2000.

30



Radium - A naturally occurring radioactive metal that exists as one of several isotopes (radium-223, radium-224,
radium-226, and radium-228), formed when uranium and thorium decay in the environment. Radium is found at low
levels in the natural environment in soil, water, rocks, coal, plants, and food."

Radon - A colorless naturally occurring, radioactive, inert gas formed by radioactive decay of radium atoms in soil,
rocks, or water.” Radon occurs as the radionuclides radon-220 and tadon-222.

Small Quantity Generators - Facilities that generate between 100 kg and 1,000 kg of hazardous waste per calendar
month."

Solid waste - Any garbage, refuse, or sludge from a wastewater treatment plant, water supply treatment plant, or air
pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material,
resulting from industrial, commercial, mining, and agricultural operations and from community activities. For the
purposes of hazardous waste regulation, a solid waste is a material that is discarded by being either

abandoned, inherently waste-like, a certain waste military munition, or recycled."!

Source material - Uranium or thorium, or any combination thereof, in any physical or chemical form or ores that
contain 0.05 percent or more of uranium, thorium, or any combination of the two. This does not include special
nuclear material (10 CFR 40.4).

Technologically Enhanced Naturally Occurring Radioactive Material - Naturally occurring materials, such as
rocks, minerals, soils, and water whose radionuclide concentrations or potential for exposure to humans or the
environment is enhanced as a result of human activities (e.g., water treatment).

Toxicity Characteristic Leaching Procedure - A laboratory procedure that simulates landfill conditions. Iris
designed to predict whether a particular waste is likely to leach dangerous levels of chemicals into groundwater and ts
used to determine whether a waste is considered hazardous under 40 CFR 261.10.

Unimportant quantity - Source material that is exempt from the licensing requirements of NRC and the Agreement
States. One exemption is for any: chemical mixture, compound, solution, or alloy in which the source material is by
weight less than 0.05 percent of the mixture, compound, solution or alloy. This exemption does not include
byproduct material as defined in 10 CFR Part 40 (10 CFR 40.13(a)).

Universal treatment standards - The constituent-specific treatment standards found in 40 CFR 268.48. The
standards must be met before hazardous waste can be land disposed.”

Uranium - A naturally occurring radioactive clement with an atomic number of 92. The principal isotopes by weight
are, in the uranium decay series, uranium-234 and uranium-238 (comprising 99.3 percent of natural uranium by mass)
and, in the actinium decay series, fissionable uranium-235 (comprising 0.7 percent of natural uranium by mass).

EPA, July 2002.

S. EPA, 1997,
“US. EPA, January 2003.

sit

EPA, January 2003,
“In accordance with concepts presented in NAS (1999) and IAEA (2004).

SUS

EPA, January 2003,

MUS. EPA, Land Disposal Restrctions Glossary, Date unknown,
AA


1-C Treatment Residuals: An Overview

Each treatment technology listed in Table 3 produces solid residuals (including spent resins, spent filter media, spent
membranes, and sludges) and liquid residuals (including brines, backwash water, rinse water, acid neutralization
streams, and concentrates).

Because disposal options may be limited, systems need to be aware of the types of residuals that will be generated by
each treatment process in order to determine whether the treatment will be practical and affordable. Table 4 outlines
the residuals produced by the BATs and SSCTs listed by U.S. EPA for radionuclide removal. For additional
information on each technology, see Section II and Appendix E of this guide.

Table 4: Residual Type by Treatment Technology

Types of Residuals
Solid Liquid
Treatment
Spent Spent Sludge | Brine | Backwash | Rinse Acid Concentrate
Resins/ | Membranes Water Water | Neutralization
Media Water
IX v v v v
RO v v
Lime Softening v v v
Green Sand Filtration v v v
Co-preeipitation with V V V
Banum Sulfate
Electrodia
Llectrodialysis Reversal v v
Pre-formed Hydrous
Manganese Oxide v v v
Filtration
AA v v v v v
Coagulation /Filtraton v v v

I-C.1 Residual Estimation: U.S. EPA Spreadsheet Program to Ascertain Radionuclides
Residuals Concentration Model

U.S. EPA has developed a Spreadsheet Program to Ascertain Radionuclides Residuals Concentration (SPARRC)
model that indicates potential concentrations of radioactivity 1n residuals and filters at the system. U.S. EPA began
developing the model in 1998. This initial version focused on developing the contaminant mass balances in the sludge
and other residuals using a complete set of input from the user. While the early version of SPARRC is useful in
estimating the volume and concentrations of residuals, it lacked capabilities to estimate the removal efficiencies.



Table E-4: Radium Removal with Reverse Osmosis — Sarasota, FL”

System Raw Wate —_— 82225 | percent
(capacity — Kgpd) TDS (mg/L) Raw Treated Reject Efficiency Recovery
Water Water Water
Bay Lakes Estates MHP (40) 2,532 3.2 O41 - 97% -
Venice (1,000) 2,412 34 0.3 7.8 2% 64%
Sorrento Shores (200) 3,373 4.6 0.2 7.9 96% 39%
Spanish Lakes MEIP (70) 1,327 10.4 1.2 20.5 88% 31%
Nokomis School (0.8) 1,442 ILL 0.5 119 95% -
Bayfront TP (1.6) 895 12.1 0.6 19.4 95% 28%
Kings Gate TP (30) 1,620 15.7 2.0 87% -
Sarasota Bay MHP (5) 2.4300 20.5 03 37.9 98% 50%
AVERAGE IG

Table E-5: Radium Concentrations in Lime Softening Sludges and Backwash Waters”

Location and Type of Wet Basis (pCi/L) Dry Basis (pCi/g)
Sludge Percent Solids

(Ra in raw water) Ra-226 Ra-228 Ra-226 Ra-228
West Des Moines, IA (9.3 pCi/L)
Lagoon Sludge 37.6% 5,159 596 10.8 13
Clarifier Sludge 1.6% < 20 <40 < 0.02 < 0.04
Lagoon Sludge N/A 2,300 N/A N/A N/A
Backwash Water N/A 63 N/A N/A N/A
Bushnell, IL
Clarifier Sludge 19% 4577 <45 21.6 < 0.21

“Sorg, T., 1980.

“Snoeyink, V., et al, 1984.



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preventing the introduction of any pollutants that may interfere with the POTW treatment process or contaminate
POTW sewage sludge. This allows POTWs to implement Technically Based Local Limits (TBLLs). TBLLs vary
among states and POTWs. Systems must check with their state and local POTW before choosing discharge to a
POTW' as a disposal option.

In addition, if systems located near ocean or saline waters wish to discharge their wastes directly to these waters, they
may be affected by the Marine Protection, Research, and Sanctuaries Act (MPRSA). Permits are required for
ocean disposal activities although having a NPDES permit may satisfy the requirements set forth under MPRSA.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

CERCLA is more commonly known as Superfund. It provides broad federal authority to respond to releases or
threatened releases of hazardous substances that may endanger public health or the environment. Systems must
consider CERCLA when selecting disposal options because they may be liable for incidents that result from disposing
of wastes at a mismanaged landfill. For example, if a system disposed of sludge containing radionuclides at an
improperly managed landfill and any release or threat of release occurred, the system could be partially or entirely
liable for the cleanup.

Department of Transportation (DOT) Regulations

Under the Department of Transportation Act of 1966, DOT has regulatory responsibility for safety in the
transportation of all hazardous materials (see 49 CFR 100-185), including radioactive material. DOT regulations
govern container design, chemical compatibility, packaging, labeling, permitting, and transportation route
requirements. This includes shipments by all modes of transport in interstate, intrastate, or foreign commerce (rail,
highway, air, water), and by all means (truck, bus, auto, vessel, airplane, rail-car) except for postal shipments, which are
under the jurisdiction of the U.S. Postal Service.

In a Final Rule (69 FR 3631) published on January 26, 2004, DOT adopted radionuclide-specific thresholds to
determine when a material containing radionuclides is subject to the DOT requirements for transporting radioactive
material. The exemption values consist both of activity concentrations and total consignment activities; a material
containing a single radionuclide would have to be above both exemption values for that nuclide in order to be subject
to those DOT requirements. If either the activity concentration or the total consignment activity is below the
corresponding exemption value, that material is exempt ftom the DOT requirements for transporting radioactive
material. The exemption values are listed in 49 CFR 173.436, and are referred to in the definition of Radioactive
Material in 49 CFR 173.403. 1f more than one radionuclide is present, the appropriate exemption values are to be
determined using a mixture rule described in 49 CFR 173.4:

In addition, in paragraph 49 CFR 173.401(b)(4), DOT exempts “natural material and ores containing naturally
occurring radionuclides which are not intended to be processed for use of these radionuclides” so long as their activity
concentrations and consignment activities do not exceed 10 times the levels listed in 49 CFR 173.436 or calculated
using 49 CFR 173.433. For example, because the exempt activity concentration for uranium is listed in 49 CFR
173,436 as 27 pCi/g, and those for radium-226 and radium-228 are 270 pCi/g, systems transporting more than 270
pCi/g of uranium or 2,700 pCi/g of radium must comply with DOT's requirements for transporting radioactive
materials (unless the consignment activities are below the consignment activity exemption values - 27 nanocuries and
270 nanocuties, respectively - in which case the material would still be exempt from those requirements). For more

information, see hutp:/“hasmat.dotgov.

Treatment plants classified as Large or Small Quantity Generators under RCRA must ensure that any waste to be
transported for disposal is handled by a U.S, EPA-approved transporter.

Low-Level Radioactive Waste Policy Act (1980) and Amendments (1985)

This Act made states responsible for disposing of LLRW generated within their borders. States are permitted to form
compacts with other states to develop LLRW disposal facilities serving more than one state. These facilities are

C2


Decision Tree 1: Solid Residuals Disposal

Mdenaly the wality Is the waste a solid No | Use termediate
and quantity © me |____g! according to the Paint - processing to
resiaua Filter Liquids Test? separate out the
. liquids
£ Yes J 4
* Sludge
Dispose ina
+ Granular Media solid waste
and fill For liquid residuals
Resin disposal, see Liquid
+ AA Media f Residuals Decision Tree
No 2
+ Spent Membranes |
Does the waste
contain
Ts the waste No radionuclides
hazardous? T
Yes
4 N Dispose in a solid waste,
No a
Yes Does the waste contain non- hazardous waste, or LLRW
exempt quantities of landfill, or any landfill
uranium or beta/ photon Yes heensed by the state to
emitters?* accept TENORM waste**
Does the waste Dispose in a hazardous
: q
contain No waste landfill and meet all
radionuclide RCRA Subutle €
I requirements**

Dispose in a
Does the waste contain non-

landfill licensed to
exempt quannties of uranium | Yes} accept mixed

waste**

Dispose in a LLRW landfill permitted to accept

hazardous waste or a hazardous waste landfill
licensed to accept TENORM waste**

* Check with the state Radiation Program to see if beta/photon emitters are considered byproduct material and advise
system to contact the NRC Regional office or relevant Agreement State agency to discuss potential licensing
requitements.

** LDR treatment standards also apply. Check with the state Radiation Program to determine the proper disposal
methods for waste containing radionuclides and hazardous waste.


climate dependent. Systems should check with their states for design guidelines, regulations, and permitting
restrictions for these processes.

Recycle of residuals, such as membrane concentrate and spent filter backwash, is also an option for systems.
During treatment with lime softening, a portion of the sludge is recycled. Systems should avoid recycle practices
that will concentrate radionuclides to levels that make disposal prohibitively expensive. In addition, the Filter
Backwash Recycling Rule (FBRR) applies to those systems using surface water or groundwater under the influence
of surface water, who recycle spent filter backwash, thickener supernatant, and liquids from dewatering processes
from conventional or direct filtration systems.

Decision Tree 3: Liquid Residuals Disposal: Intermediate Processing

Idenuty che
quality and
quantity of the
residual

i

Is the waste a solid according
Pt the Paine Futer Liquids [4
' Test? See the Solid
No Yes Residuals

4 LA} Decision Tree

+ Filter Backwash & Filter-to-
Waste
* Concentrate Reevele
+ Brine
+ AA/IX Backwash and Rinse
Waters
+ Acid Neutralizauon
* Liquids From Dewatering
Can the liquid be Yes
an the liquid be re-
introduced to the Will the liquid
main treatment train residual require
(recy cle)? [——— Ne > intermediate
No processing?
+
Yes
See Liquids Residual
Decision Tree 2
t Liquid waste Solid waste

stream stream
generated generated

35


Table E-2: Radium-226 Concentrations in Jon Exchange Treatment Plant Wastes”

Average Ra-226 Concentration (pCi/L)

. Peak Ra-226
Location Concentration in
(Ra-226 in raw water) | 5 . Brine + Rinse + Peak 1/4-1/3 of °
+ Ri
vine mse Backwash Regeneration Cycle Wastes (pCi/L)
Eldon, IA
530 420 2,000 3,500.
(46 pCi/L) 2000
Estherville, [A
N/A 52 114 320
(6 pCi/L) N/ (
Grinnell, LA
. 110 N/A 260. 320,
pCi/L) / .
Holstein, LA
i" 7 A 57
(13 pCi/L) 175 N/. 6 1,100
Quail Creek, TX
Quall Creek, NA 93 190 200
(7.3 pCi/L)
Table E-3: Uranium Removal with Anion Exchange*
Concentration, of Uranium (ug/L) Gallons Bed Capacity (lbs
Location
Raw Water Treated Water! Treated u/fe)
Cove, AZ 64 63 31,400 0.017
Fort Lupton, CO 35 35 22,310 0.007
Brighton, CO 23 23 45.460. 0.009
Marshdale, CO 28 <0.1 40,610 2
Church Rock, NM 52 Ol 20,360 °

* Uranium concentration of treated water measured after indicated number of gallons treated

2 Bed capacity nor exhausted

*Schuekelman, R., 1976; U.S. EPA, 1992,

“Lassovszky, P. and Hathaway, S., 1983.



Contents

Acknowledgments ... 00.66.06 c enn nent een eee teen ete eee eens iil
Executive Summary... 66.6 eee Eten teen E nett e eens v
ACEOMYMS oe En nL nent nent eet e ene viii
Introduction 6. nee EEE nee eee n eee 1
Section I: Overview of the Removal of Radionuclides from Drinking Water... 200.0666 coe cece eee 4

I-A Determining Whether Additional Treatment is Appropriate: Compliance Options Overview ......... 4

I-B Choosing the Right Technology: An Overview of Listed Best Available Technologies and Small Sy

Compliance Technologies 25

I-C Treatment Residuals: An Overview .. .7
T-C.1 Residual Estimation: U.S. EPA Spreadsheet Program to Ascertain Radionuclides Residuals

Concentration Model 6.0.6... eee eet e eect nett eee e ee 7

I-D__ Disposal of Residuals: An Overview of Applicable Statutes, Regulations, and Disposal Options . 9

LD.1 Applicable Federal Statutes and Federal Regulations ....0.0.0.0.000000c0ceeceteee eter ees 9

I-D.2 Applicable Federal Definitions for Waste . . 11

T-D.2.1 Hazardous Waste ........... iW

1-D.2.2 Low-Level Radioactive Waste . 12

1-D.2.3 Mixed Waste : 13

I-D.3 Possible Disposal Options if Elevated TENORM 1s Present ... . 13

I-D.3.1 Options for Disposal of Solid Residuals ... .

I-D.3.2 Options for Disposal of Liquid Residuals .

I-E Worker Exposure and Safety ..
I-E.1 Radiation Surveys ....

I-E.2 Radiation Exposure Due to Water Treatment Operations

1-E.3 Additional Safety Considerations ©... 06.06.06. c ccc te eens .. 26
Section I: Treatment Technologies Overview . 06.6066 cence nee e cette etn eee 7

II-A Treatment Methods, Residuals, and Disposal Considerations .
IL-B Intermediate Processing

Appendix A: Glossary oo .0 e620 c ccc b ete cnet eee cee nee e tne e edt te eee tbe beter et ne neteteneterer sees Al
Appendix B: References 00.06.06 c eee ee eee etn ence nent eee e ee B-1
Appendix C: Applicable Federal Statutes and Regulations ©... 0.26.0... eect eee cette tenet nee Cl
Appendix D: State, Regional, Federal, and Tribal Contacts 000.000. ccce cece cece ee ecs eee eee cese este ees D-1
Appendix E: Radionuclide Levels at Selected Water Treatment Plants 2.2.0... 6 06.000 cece eect eee e eens E-1
Appendix F: Thorium and Uranium Decay Seties 1.2.0.6... eee eee cette eet e neces F-1
Appendix G: Additional Reference Materials «1.0... 6-062 066 c cece eet tte nt ete eee G-1


Table E-7: Concentration of Radionuclides on Water Treatment Process Media and Materials”

Radionuclide Concentration

. Process (pCi/g)
Location Treatment Process Media/Material
Ra-226 Ra-228
Herscher, [L Tron removal Filter media 111.6 38.9
Dwight C al
Nwigne Corrections Natural green sand Green sand 29-46

Institute, IL. .

Peru, IL Lime softening Filter media 4.6 3.6

Elgin, IL Lame softening Filter media 16.0 8.3
Elkhorn, WI Iron removal Filter media (sand) 147 0.48

Bennett, D.L., 1978, Brink, W.L., et al, 1978.



Table E-5, Continued

Location and Type of Wet Basis (pCi/L) Dry Basis (pCi/g)
Sludge Percent Solids

(Ra in raw water) Ra-226 Ra-228 Ra-226 Ra-228
Clarifier Sludge 12.6% 2,038 236 15.0 17
Backwash Water 0.23% < 20 <39 N/A N/A
Webster City, IA (6.1 pCi/L)
Shudge N/A 980 N/A N/A N/A
Backwash N/A 50 N/A N/A N/A
Peru, IL (5.8 pCi/L)
Backwash Water N/A 36.9 N/A N/A N/A
Elgin, IL (5.6 pCi/L)
Lagoon Sludge 57.3% 9,642 9,939 113 17
Clarifier Sludge 10.3% 948, 873 8.6 8.0
Backwash Water 0.05% < 20 < 40 < 0,02 < 0.04
Sludge NA 18.3 N/A N/A N/A

Table E-6: Concentration of Radionuclides in the Spent Filter Backwash from Green Sand Filtration and
Other Iron/ Manganese Filtration Processes”

Raw Water Spent Filter Backwash Water
Plant Ra-226 Ra-228 | Uranium | Ra-226 |  Ra-228 Uranium
(pCi/L) (pCi/L) (pCi/L) (pCi/L) (pCi/L) (pCi/L)
Sandstone ' 9.2 5.2 0.13 40.6 274 Lu
Hinckley ? 76 45 0.14 270 304 23
Madelia > 21 39 <0.14 108 170 < 0.20
Inver Grove Heights ! 53 1 0.62 145 5.9 031
Savage? 75 8.1 04 699 54.4 0.98

' Treatment scheme consists of chlorination, potassium permanganate, and anthracite/sand filter
“Treatment scheme consists of aeration, chlorination, potassium permanganate, and anthracite/green sand filter

“Treatment scheme consists of aeration, chlorination, detention, potassium permanganate, and anthracite/sand filter

“Peterson, K. 1999.
B4


238:
92
45x10? years

Figure F-2: Uranium Decay Series

ig

a

Bay,
0
24 days

hn,

Ba

2
2.5x10° years

o1

6.8 hours

24,
4

1.6x104 seconds

210,

138 days

210g,

5 days

214,

27 minutes

210y,
82

22.3 years

2006,
82
Stable



Table 8: IX and POU IX Overview

IX 1s listed as a BAT for radium, uranium, and beta partcle and photon activity removal.
Anion exchange (AX) resins remove urantum; cation exchange (CX) resins remove radium
and soften water. Mixed bed IX is suitable for beta particle and photon activity removal.
Use SSCT IX and POU IX are listed as SSCTs for systems serving 25-10,000 customers for radium,
uranium, and beta particle and photon activity removal. POU IX units treat water from a
specific tap and must be owned, controlled, and maintained by the water system or a system
contractor. .
Effvien AX removes up to 95% of uranium;” CX removes up to 97% of radium."
ad See also Appendix E, Tables 1-1, E-2, and E-3
Liquid Backwash water, brine (volume varies according to raw water quality, unit size, regenerant
5 on ‘ation a lia ca ity), a ise Wa
Residuals concentration and media capacity), and mnse water
Solid Spent resins
Additional Direct > Normally not an option due to high TDS levels and high contaminant concentrations
Disposal discharge | » Blending brine with backwash and rinse can significantly reduce radionuclide
Issues* concentrations and TDS but usually not to levels that would allow for direct discharge
Regeneration of CX resins may not remove all radtum from the resin, complicating disposal
Using potassium chloride as a regenerant can increase the efficiency of CX resin regeneration
ere Systems should conduct pilot tests of [X treatment to determine a regeneration schedule
Limitations 5 , ce
Some states do not allow systems to run IX resins to exhaustion for uranium removal
Radionuclides may become so concentrated in the brine and resin that they may require special handling
and disposal procedures

*All of the common

disposal considerations in ‘Table 7 must also be taken into account.

*"Lassovszky, P. and Hathaway, S., 1983; Hanson, S , et al, 1987, U.S. EPA, 1992.

*'Schliekelman, R., 1976; U.S. EPA, 1992a; U.S. EPA, 1977; Brink, W.L., et al, 1978; Lassovszky, P. and Hathaway, S., 1983; U.S.

EPA, 1992.



Table 5: Disposal Options by Type of Residual Produced

Disposal Options
Residual Waste
Direct Discharge } Recycle’ | Underground | Landfill
Discharge | to POTW Injection
Liquid Wastes
Acid Neutralization v v v v
Water
Backwash Water v v v v
Brine v v v v
Concentrate v v v v
Rinse Water v v v v
Solid Wastes
Sludge v v v
Spent Media v
Spent Membranes v

E-D.3.1 Options for Disposal of Solid Residuals

Depending on the characteristics of the waste, state and landfill-specific disposal restrictions, cost, and system
location, solid waste may be disposed of in a solid waste (RCRA Subutle D), LLRW, or hazardous waste (RCRA
Subtitle C) landfill. See Decision Tree 1 on page 17 of this guide for an overview of the decision making process for
systems that generate solid residuals. Systems should also be aware that landfill owners can refuse to accept any waste
and have the discretion to return any waste to the generator.’*

US. EPA is aware that some states allow land spreading or soil mixing as an alternative to landfill disposal for water
treatment residuals (for example, as a soil amendment on farm fields). One central concern with land spreading 1s the
potendal 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 muluple 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.

Other options such as incineration, evaporation ponds, surface impoundments, and sludge dewatering are merely
intermediate processing methods; each creates its own residual stream, Additional information appears in Section II-B
of this guide, “Intermediate Processing.” States should consult their relevant waste disposal programs to determine an
appropriate disposal option for systems generating solid residuals containing radionuclides. See Appendix D for
contact information.

“Phe return of the quid waste stream into the water system’s treatment process.

'SPlease note that if'a load 1s rejected and the material 1s not denufied, DOT exemption paperwork nceds to be filled out by a state
radiation protection of radiation control employee prior to the load going back on the road. More information about this can be
found at the CRCPD Web site ats atipy vay erepdony/Franypor ation telatecd does asp

14



US. EPA regional or state UIC program office for any additional state-specific UIC requirements. For additional
information, systems should be referred to the appropriate U.S. EPA regional, state, or tribal UIC program listed in

Appendix D.
Table 6: Underground Injection of Liquid TENORM Residuals
Class Use Considerations
I Used to place radioactive, hazardous, or > — Class I wells have stringent protective requirements to

non-hazardous fluids (industrial and municipal
wastes) into deep isolated formations beneath the
lowermost USDW’.

There are 272 Class | injection facilities nationwide.

For more information see:
lupe An wwe cept

ichassihiml

nv /safewater!

ensure safe injection

+ Very few Class I facilites are commercial (able to accept
hazardous or mixed waste generated off-site for
injection)

> — Disposal of slurries and solids is allowed in only limited
circumstances because of the potential to fracture the
receiving formation

> — Class I wells can be expensive to construct because they
are technically complex

LIV.

‘These are generally shallow wells (e.g, large
capacity septic systems and dry wells) used to place
a variety of non-radioactive, non-hazardous fluids

into or above USDWs.

I Used to place produced water and other fluids 1n Not an option
connection with oil and gas production.
M1 Used for mineral extraction. Not an option
IV Shallow wells used to inject hazardous or > — Class [V wells were banned in 1984.
radioactive waste into ot above a USDW. > — Not an option
Vv Includes injection activities not described in Classes | » — Not an option for hazardous or radioactive waste

disposal

> — Use of class V wells is prohibited if it will endanger a
USDW per CFR 144.12 (cause an exceedance of any
primary drinking water standard or otherwise adversely
affect public health)

> Class V wells must also comply with state specific UIC
requirements, which may be more stringent

20



L-D.3.1.3.2 Hazardous waste landfills

Systems using treatment technologies that remove contaminants such as arsenic, in addition to radionuclides, could
potenually generate hazardous waste. Hazardous waste from Large and Small Quantity Generators must meet RCRA
Land Disposal Restriction treatment standards (40 CFR 268.40) prior to disposal in a hazardous waste landfill.
Facilities permitted under Subtitle C may accept hazardous waste (though not mixed waste) from all generator classes,
and vary in their ability to accept TENORM wastes. If hazardous residuals contain source material above 0.05% in
weight or other AEA materials they must be disposed of at a facility authorized to accept mixed waste.

Hazardous waste landfills accept hazardous waste from all generator classes, and vary in their ability to accept
TENORM wastes. 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. Systems should check with the

disposal facility to determine whether their TENORM waste is eligible for disposal at a particular hazardous waste
landfill.

1-D.3.1.3.3 Low-level radioactive waste landfills

LLRW landfills may be an option for systems generating wastes with radionuclide concentrations deemed to be
unacceptable for disposal at a solid or hazardous waste landfill. LLRW landfills are licensed by NRC or by a state
under agreement with NRC, and guidelines for disposing of radioactive sludges and solids are more stringent than in a
standard landfill. These facilities are licensed based on projected performance and have packaging and burial
requirements that are progressively stricter as the radionuclide concentrations increase.

There are three LLRW disposal facilities currently in operation:

Barnwell - Will, after June 30, 2008, accept LLRW only from organizations in South Carolina, Connecticut, and New
South Jersey. For more information, including waste transport, disposal rates, and site availability, see

Carolina Sap! Avuw varcoc.us/encroy/RadWasio/nidp indes.bim,

Richland - Accepts certain types of TENORM (although not hazardous or mixed) wastes from alll states. Accepts
Washington licensed source material only from the 11 states in the Northwest and Rocky Mountam Compacts. State

regulators anticipate including acuvity limits for urantum-238 and radium-226 in the facility's renewed
license. For more information, including w: ailabiltty,

ec

te transport, disposal rates, and site a

beep: Aww cevawa gov “programs ‘nw lew ‘ling htm.
Envirocare - Has dedicated TENORM disposal and is the only LLRW landfill authorized to accept certain kinds of mixed
Utah waste. Does not accept LLRW from Northwest Interstate or Rocky Mountain Compact states. Por more

information, see hep: www em irocareurb.com.

The Low-Level Radioactive Waste Policy Act gave states the authority to form regional compacts to manage their
commercial LLRW. Compact authority generally extends to the import and export of waste to and from states in the
compact. If water treatment plants are licensed by the NRC or Agreement State, their disposal options may be
limited. Systems should be made aware that compacts may have requirements beyond those of the NRC or
Agreement State. For more information on interstate compacts and Agreement States, see http:/
ne do/smate mbal/agreemenr states.html.

senrevos /whar-

16


Table 9: RO and POU RO Overview

BAT RO 1s listed as a BAT for radium, uranium, gross alpha particle activity, and beta particle and
photon acuvity and is also effective at removing other inorganic contaminants, such as heavy
metals

SSCT | RO is listed as a SSCT for radium, gross alpha, and beta particle and photon activity for

Use systems serving 25-10,000 customers, and for uranium for systems serving 501-10,000
customers. POU RO 1s. SSCT for radium, uranium, gross alpha particle activity, and beta
particle and photon activity for systems serving 25-10,000 customers. POU RO untts treat
water from a specific tap, and must be owned, controlled, and maintained by the water
system or a system contractor.

5 > RO can remove at least 90% of these radionuclides from drinking water
Efficiensy |, See also Appendix E, Tables E-1 and E-4 °
ee also Appendix E, ‘Tables E-1 and E:
Liquid Concentrated liquid waste stream
Residuals
Solid Spent membrane

> Using RO necessitates having a highly skilled operator

> Residuals produced can have very high concentrations of the contaminants removed from the water,
Limitat including radionuclides, which may limit disposal options. The concentration depends on the efficiency

imitations

of the RO

unit: highly efficient units will produce low volumes of residual streams with high

concentrations of contaminants while lower efficiency units will produce higher volumes of residual
streams with lower concentrations of contaminants.

29



State TENORM Regulations

States address TENORM in various ways. Although thirteen states currently have regulations addressing TENORM,

some only regulate TENORM from specific industries (e.g,, otf and gas or phosphate production), while others address

all sources of TENORM. For example:

* In Maine, non-exempt facilities abiding by the state’s standards for TENORM radiation protection, worker safety,
disposal and transfer of waste, dilution of wastes, and unrestricted use and conditional release, may receive a license
to transfer or dispose of TENORM wastes without quantity restrictions (10-144 CMR 220, Subpart N).

* Louisiana issues similar licenses to non-exempt facilities and requires that a manifest be obtained from the
Department of Environmental Quality prior to shipping TENORM waste to a disposal facility (LAC 33:XV.1408
and 1418).

* — Texas also issues general licenses to non-exempt facilities. Systems transferring waste for disposal must choose a
facility licensed to accept TENORM wastes (25 TAC 289.25(6) and (h)).

Most states do not have specific TENORM regulations and regulate it the same way as all other sources of radiation. For
more information on state regulations, see hup./ www senorm.com/ivgs2.bim/Stures,

The remainder of this section and Appendix C contain additional information on these and other applicable federal
statutes and regulations as they apply to the disposal of water treatment plant residuals containing radionuclides.
States may have additional requirements or restrictions on the disposal of water treatment residuals containing
tadionuclides. State radiation, hazardous waste, and drinking water programs should coordinate to provide systems
with comprehensive information on all relevant requirements (see Appendix D for state contact information).

I-D.2 Applicable Federal Definitions for Waste

Systems should be aware that key definitions vary among regulauons. For example, the UIC progam’s regulations do
not automatically assume the same exemptions as the NRC regulations (¢.g., source material is of an “unimportant
quantity” (10 CFR 40.13) and 1s exempt from NRC regulation if the uranium or thortum makes up less than 0.05
percent by weight of the material. For natural uranium, this 1s approximately 335 pC1/g, though this figure is an
estimate and actual values may be obtained for different uranium and thorium isotopes). Making systems aware of
these distinctions is important in ensuring that they adhere to all applicable federal statutes and regulations. In
addition, systems should be made aware of any state lensing requirements related to the generation of non-exempt
radioactive materials.

ED.

Hazardous Waste

Hazardous waste is defined under 40 CFR 261.3. Waste ts considered hazardous if it is a solid waste (as defined under
40 CFR 261.2) that is not excluded from regulation as hazardous waste under 40 CFR 261.4(b) and when it meets the
criteria listed under 40 CFR 261.3(a)(2) and (b). The RCRA regulations establish two ways of identifying wastes as
hazardous under RCRA. A waste may be considered hazardous if it exhibits certain hazardous properties
(“characteristics”) or if it is included on a specific list of wastes EP.\ has determined are hazardous (“listing” a waste
as hazardous in 40 CFR 261.31 to 261.33). RCRA defines four hazardous waste characteristic properties: ignitability,
corrosivity, reactivity, or toxicity (see 40 CFR 261.21-261.24). The hazardous waste characteristics are most applicable
to TENORM waste; the toxicity characteristic (40 CFR 261.24) is likely to be the most concern for generators of
TENORM wastes.

The presence of radionuclides does not make waste hazardous; hazardous waste generation will most likely be the
result of the removal of co-occurring contaminants, such as arsenic, in the waste. Some treatment technologies that
are effective in removing radionuclides (e.g., EX) will also be effective in removing other contaminants (e.g., arsenic)
that, in high enough concentrations, could make the resulting residuals hazardous or, in some cases, mixed waste. For
more information, see Regulations on the Disposal of Arsenic Residuals from Drinking Water Treatment Plants (EPA/600/R-

inl


Appendix F: Thorium and Uranium Decay Series

22,
”

1.4810!" years

Figure F-1: Thorium Decay Series

11 hours

Fel

212),
&
3x10" seconds
Bo5%
2%, a
83
0 minutes
a 208»,
35% 82
Stable
208),
81
3.1 minutes 8



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3. Details on the residual streams produced by these treatment technologies.
4, General options for disposal of the residuals produced by these treatment technologies.

5. Information on key issues related to the disposal of drinking water treatment residuals contaming regulated
radionuclides, including co-occurrence, applicable federal regulations, and worker safety concerns.

This guide has two main sections:

Section I provides an overview of the removal of radionuclides from drinking water and a discussion of worker
safety. It is an introduction to non-treatment options, treatment technologies, residuals, disposal options, and
measures that systems can take to protect their staffs from radiation exposure.

Section II provides a more in-depth review of treatment technologies, the residuals they produce, the disposal
options for these residuals, and intermediate processing,

In addition, the appendices include a glossary, a list of references and contacts for more information, and a catalogue of
resources that provide more information on the Radionuclides Rule and on the treatment, handling, and disposal of
radionuclides.

MCLs,



control access to areas where radiation levels are high or very high (10 CFR 20.1601 and 1602), and sets restrictions on
the use of individual respiratory equipment (10 CFR 20.1703 and 1704), among other things.

Part 20 also sets requirements related to storage and control of licensed material, including posting, signage, and
labeling requirements (10 CFR 20 Subparts I and J), These regulations stipulate that licensees’ radiation protection
programs be designed around the ALARA principle and require licensees to limit air emission of radioactive material
(excluding radon-222 and its daughters) so that the highest total effective dose equivalent received by any member of
the public is no greater than 10 mrem/year. Part 20 also sets notification requirements in the case of an incident at the
licensed facility or for cases in which the facility is required to report exposutes, radiation levels, or concentrations of
radioactive materials exceeding constraints or limits (10 CFR 20.2201 to 2203). Consult with your NRC regional
office or relevant state agency to ensure that any licensed facilities in your state are aware of these additional worker
safety requirements.

I-E.3 Additional Safety Considerations

Radon is a natural decay product of radium and other radionuclides. Jt can vary in concentration by time of day or
seasonally. It is appropriate for systems to consider radon protection measures when handling wastes containing
radium. U.S. EPA recommends that action be taken to reduce radon levels 1n homes and schools where testing shows
average concentrations of 4 pCi/L or greater. Although exposure to radon in homes or schools is evaluated
differently than occupational exposure, many nations and the ICRP recommend that intervention levels for exposure
to radon in homes also be used in workplaces." U.S. EPA recommends that the action level used for homes and
schools be used for water systems.

If radionuclides or radiation have been found in drinking water or at a system, having operators who are trained in
treating for radionuclides, and handling, disposing of, and transporting TENORM waste, is highly recommended. In
addition, determine whether your state requires someone specifically licensed by the state or NRC to handle these
types of residuals. Operators should also be trained in how to measure radioactivity levels. Encourage systems to
check with the relevant state office regarding licensing requirements and training opportunities.

Assistance and advice are available from the appropriate State Radiation Control Program (see Appendix D), the
Conference of Radiation Control Program Directors at http://w ww.crepd.org, and the U.S. EPA Regional Radiation
Programs. For additional references on this and other topics discussed in this guide, see Appendix G.

“ICRP, 1993.
26


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Appendix E: Radionuclide Levels at Selected Water Treatment Plants

A variety of studies between 1982 and 1995 found that commonly used filtering methods and media for radionuclides
at water treatment plants may concentrate uranium and radium at highly different levels of radioactivity. Depending
on the radiation level of the water to be treated, as well as the treatment process, residuals and filters can accumulate
radionuclides in the range of less than 10 pCi/g or per liter, to thousands of pCi/g or per liter. The method chosen
for filtering water may have a significant impact on the radiation protection program that may need to be instituted at
the treatment facility and available waste disposal options. Table E-1 summarizes the ranges of radium and uranium
concentrations found nationwide in different filter media and backwash. Additional findings from water treatment
plants follow in Tables E-2 to E-7.

Table E-1: Summary of Treatment Technologies for Removal of Naturally Occurring Radionuclides in

Water
Treatment Contaminant Removal Wastes Waste
Technology Removed Efficiency Produced Concentrations
Cation exchange Radium 85-97% Rinse & backwash water 8 to 94 pCi/L-Ra!
Regenerant brine 50 to 3,500 pCi/L-Ra!
22 to 94 pCi/L?
Anton exchange Uranium 95% Rinse & backwash water 2 to 6e+06 pCi/L!-U
Brine regenerant solution 35 to 4.5e+06 pCi/LEU
1.3 to 11 pCi/L
Lime softening Radium 90% Sludge (at clarifier 76 to 4,577 pCi/L-Ra
Uranium 85-90%" Sludge (dry) 1 to 21.6 pCi/g-Ra
1 t0 10 pCi/g-U
Filter backwash 6.3 to 21.9 pCi/L-Ra
Reverse osmosis Radium 90+% Reject water 7 to 43 pCi/L-Ra
Uranium o 200 to 750 pCi/L-U
Electrodialysis Radium 90% Reject water No data
Uranium —
Iron removal Radium 0 0 70%" Solids & supernatant from filtration 12 to 1,980 pCi/L-Ra
-Oxidation backwash
-Greensand Green sand Media 28 to 250 pCi/g-Ra
Selecuve Radium 04% Selective sorbents (radium selective up to 3.6 pCi/g-Ra
sorbents Uranium, and activated alumina)
Coagulation/ Uranium 50 to 85% — | Sludge 10,000 to 30,000 pCi/L-U
Filtration

D
Peak values

* Average for given waste forms

3
May be increased to 99% by the presence or addition of magnesium carbonate to the water

* May be increased to 90% by passing the water through a detention tank after the addiuon of potassium permanganate prior co filtration,

Data extracted from U.S. EPA 1982, 1986, 1994b, 1995; Wade Miller Associates 1991; and Reid 1985
E-t


Although designed for post-cleanup surveys of radioactively contaminated sites, U.S. EPA's Multi-Agency Radiation
Survey and Site Investigation Manual (MARSSIM) (EPA 402-R-97-016 Rev. 1) 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 U.S. EPA’s Radiation Protection Division Web site at

hip:

ssim.

Awww cpa.goy /radiauor

Seven federal and two state agencies contributed to the development of MARLAP. MARLAP provides guidance for
the planning, implementation, and assessment phases of projects that require laboratory analysis of radionuclides. This
guidance 1s intended for project planners, managers, and laboratory personnel and provides extensive detail on the
radiological sampling and analytical process, including laboratory procedures. A copy of the manual can be found at:
adianon/ marly

http://www.

U.S. EPA also recommends that the system check for the presence of radon in buildings encasing system equipment.
States should consult with radiation program staff to determine whether radon measurements have been taken in the
county, whether a map or survey of indoor radon measurements has been developed for the county, where the system
is located, and to determine the appropriate means and methods for conducting radon surveys. The state or private
radon proficiency programs may be able to provide a list of licensed or certified radon contractors who could conduct
the survey. Additional information on how to find qualified professionals can be found at

bup: |.

rows tag/ radon/ proficiency |

For U.S. EPA guidance documents on approaches to risk assessments of soil and water, see the Superfund Radiation
Web sites at hup:/ rauiiauon and
berp:/ Awww epagoy “super fund ‘resources /radianon Awhatsnew him.

ror /superturd/resour

wy cp:

I-E.2 Radiation Exposure Due to Water Treatment Operations
The following discussion applies only to systems where there is the potential for accumulation of radioactivity.

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; during 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, and flocculation and sedimentation tanks where residual sludges accumulate;
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 radiation can also occur at residuals processing or
handling areas at the system and off-site locations such as landfills where residuals are shoveled, transported, or
disposed of.

The table below shows the three primary paths of radiation exposure at a system: inhalation, ingestion, and direct
exposure.

Pathway Concern

Inhalation Inhalation of alpha- or beta-emitting radioactive materials is a concern because radioactive
material taken into the body results in radiation doses to internal organs and tissues (¢.g.,
lining of the tungs). Workers could inhale radioactively contaminated dust or water droplets
while dealing with residuals or duting normal filter operations. Cleaning methods such as ait
scour, high pressure water sprays, and backwash operations can increase suspension of
radioactively contaminated water, dusts, and particulates in respirable air, thus increasing the
potential hazard of inhalation or ingestion. Workers can inhale radon and tts progeny in both
wet and dry conditions. Simple dust masks may not provide adequate protection from
exposures via this pathway, and systems may need to implement Occupational Safety and
Health \dministration (OSHA) requirements for respirators.

23



Acronyms

AA Activated Alumina

AEA Atomic Energy Act

ALARA As Low as Reasonably Achievable
AX Anion Exchange

BAT Best Available Technology

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CESQG Conditionally Exempt Small Quantity Generator

CWA Clean Water Act

CWS Community Water System

CX Cation Exchange

DOT Department of Transportation

US. EPA United States Environmental Protection Agency
FBRR Filter Backwash Recycling Rule

HMO Hydrous Manganese Oxide

ICRP International Commission on Radiological Protection
ISCORS Interagency Steering Committee on Radiation Standards
IX Ton Exchange

LLRW Low-Level Radioactive Waste

MARLAP — Multi-Agency Radiological Laboratory Analytical Protocols Manual
MARSSIM — Multi-Agency Radiation Survey and Site Investigation Manual

MCL. Maximum Contaminant Level

MPRSA Marine Protection, Research, and Sanctuaries Act

MSWLF Municipal Solid Waste Landfill

NCP National Oil and Hazardous Substances Pollution Contingency Plan
NCRP National Council on Radiation Protection and Measurements
NPDES National Pollutant Discharge Elimination System

NRC Nuclear Regulatory Commission

OGWDW — Office of Ground Water and Drinking Water

OSHA Occupational Safety and Health Administration

PFLT Paint Filter Liquids Test

POTW Publicly Owned Treatment Works

POU Point of Use

PPE Personal Protection Equipment

RCRA Resource Conservation and Recovery Act

RO Reverse Osmosis

SDWA Safe Drinking Water Act

SPARRC Spreadsheet Program to Ascertain Radionuclides Residuals Concentration
SSCT Small System Compliance Technology

TBLL Technically Based Local Limit

TCLP Toxicity Characteristic Leaching Procedure

TDS Total Dissolved Solids

TSS ‘Total Suspended Solids

TENORM _ Technologically Enhanced Naturally Occurring Radioactive Materials
UIC Underground Injection Control

USDW Underground Source of Drinking Water

viit


List of Tables

Table 1: Radionuclides MCLs 1.0... 60 c ec rr ee r eee e tert entrees 1
Table 2: Average Annual Exposure to Radiation ee

Table 3: Applicability of Best Available Technologies and Small System Compliance Technologies
Table 4: Residual Type by Treatment Technology .....
Table 5: Disposal Options by Type of Residual Produced .......

20

Table 6: Underground Injection of Liquid TENORM Residuals .
Table 7: Common Disposal Considerations for Residuals Produced by BATs and SSCTs 27
Table 8: IX and POU IX Overview .....

Table 9: RO and POU RO Overview ...
Table 10: Lime Softening Overview
Table 11: Green Sand Filtration Overview .
Table 12: Co-precipitation with Barium Sulfate Overview .
Table 13: Electrodialysis /Electrodialysis Reversal Overview
Table 14: Pre-formed Hydrous Manganese Oxide (HMO) Filtration Overview
Table 15: AA Overview ................
Table 16: Coagulation/ Filtration Overview .
Table 17: Intermediate Processing Options .
Table D-1: Regional and State Drinking Water, UIC, and Radiation Control Contacts .. .
Table D-2: Tribal Drinking Water Contacts D-16
Table D-3: Tribal UIC Contacts .......... . D-17
Table D-4: Regional NRC Contacts for Non-Agreement States... 20.0.0 D- 18
Table E-1: Summary of Treatment Technologies for Removal of Naturally Occurring Radionuclides in Water .. .
Table E-2: Radium-226 Concentrations in Ion Exchange Treatment Plant Wastes .
Table E-3: Uranium Removal with Anson Exchange .....--.....-+
Table E-4: Radium Removal with Reverse Osmosis — Sarasota, FI.
Table E-5: Radium Concentrations in Lime Softening Sludges and Backwash Waters ......- 062.0000. 22 sees
Table E-6: Concentration of Radionuclides in the Spent Filter Backwash from Green Sand Filtration and Other
Iron/Manganese Filtration Processes ..
Table E-7: Concentration of Radionuclides on Water Treatment Process Media and Materials

- 30
30
23d

31
32
32
33
.. 34
. D-1

List of Figures

Decision Tree 1: Solid Residuals Disposal .
Decision Tree 2: Liquid Residuals Disposal.
Decision Tree 3: Liquid Residuals Disposal: Intermediate PHOCESSING ©... ent e nent eee 35



00/025), Treatment of Arsenic Residuals from Drinking Water Removal Processes (EPA/600/R-01/033), and U.S. EPA’s
Arsenic Web page, at http:

Awww. epa.vov/safewater/arsenic.huml.

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 may involve
leachate tests such as the Toxicity Characteristic Leaching Procedure (TCLP) (Method 1311, as desctibed in U.S. 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.

Hazardous waste generators are classified as Large Quantity Generators, Small Quantity Generators, or Conditionally
Exempt Small Quantity Generators,!’ depending on the amount of hazardous waste produced monthly and the
amount of hazardous waste stored on site at any given tme. RCRA requirements vary for each generator class. For
more information on these requirements, see Section III, Chapter 3, of the RCRA Orientation Manual (EPA 530-R-02-
016) at hrtp:/ www.ep: woswer/ general /orientat/rom33.pdf.

A hazardous waste generator is always liable for the waste. In the event of future problems at the disposal site or with
inappropriate handling, the generator remains partially liable.

LD.2.2 Low-Level Radioactive Waste

The Low-Level Radioactive Waste Policy Act (42 USC 2021b(9)) defines low-level radioactive waste (LLRW) as
“radioactive material that (A) is not high level radioactive waste, spent nuclear fuel, or byproduct material (as defined
in section 2014(e)(2)...); and (B) the Nuclear Regulatory Commission...classifies as low-level radioactive waste.”
Generally, LLRW can be thought of as byproduct material as defined in 42 USC 2014(e)(1) (.e., yielded in or made
radioactive by the production or use of special nuclear material) that does not fall into any other category. In addition,
LLRW can contain source or special nuclear material. Note that water treatment residuals would of meet the
definition of byproduct material as defined under 42 USC 2014(¢)(2) (waste from processing uranium or thorium ore).

Radium is not considered source material and would not be considered byproduct material when present in water
treatment residuals. Uranium and thorium are considered “source material” (42 USC 2014(z)) and are subject to NRC
or Agreement State licensing and regulation. However, source material is of an “unimportane quantity” (10 CFR
40.13) and is exempt from NRC or Agreement State regulation if the urantum or thorium makes up less than 0.05
percent by weight (or approximately 335 pCi/g for natural uranium) of the material. These limits apply to both liquid
and solid residuals. For perspective, in a system with filter media weighing 30,000 pounds, 0.05 percent by weight
would be equal to 15 pounds of uranium.

If a system has source material that contains more than 0.05 percent uranium or thorium by weight, and has a total of
no more than 15 pounds in its possession at any time, it is considered to have a “small quantity” of source material
and is subject to the general license requirements of 10 CFR 40.22 or equivalent Agreement State regulations. (Note
that the 0.05 percent level is not health-based.) Under this general license, systems may not possess more than 150
pounds of source material in any one calendar year. Source material held under this general license normally requires
disposal at facilities authorized to accept LLRW. In addition, although not licensable by itself, radium that co-occurs
with licensable source material would be subject to the requirements of that license.

Systems that exceed the unimportant quantity and small quantity thresholds must apply for specific licenses from the
NRC or Agreement State.

¢ not subject to many RCRA requirements, they are subject to limited generator waste management standards (40 CER
mpt Small Quanuty Generators must idenufy their hazardous waste, comply with storage limit requirements, and ensure waste
tare permitted oF licensed solid waste landfill,

While these generators a

261.5). Condiuonally E;

treatment or disposal in a landfill that 1s permntced under Subutle C, a state MS
12



energy (¢.g., microwaves or radiowaves) and “bounces off or passes through matter without displacing electrons.”* Its
effect on human health is undetermined.

The four most common types of ionizing radiation are:

Table 2: Average Annual Exposure to
> Alpha radiation (emitted by radon, thorium, and Radiation

uranium), which can occur naturally or as the result

of manmade activities. It cannot penetrate the skin Radiation Average Typical
ea : : Source Exposure Range of
but can be a significant internal hazard if alpha- epee. 2
we Pn . Variability’
emitting radionuclides are ingested or inhaled.
(mrem/yeat)

> Beta tadiation emitted by radium-228 and
manmade contaminants from industrial uses of
radioactive materials or facilities disposing of

Natural Sources

t ' Terrestrial 30 10-80
radioactive material. It can penetrate outer layers
of skin, but beta-emitting radionuclides are more of Radon 200 30-820
a concern as an internal hazard if ingested or se
. Cosmic 30 20-100
inhaled.

Internal 40

> Gamma radiation, also referred to as “photon”
emissions (radium-226 emits both alpha and Man-made Sources
gamma radiation). Gamma radiation originates

. . - Medical 50
from processes inside the nucleus. Radioactive
materials that emit gamma radiation are of concern Consumer 10
because the gamma rays pose an external radiation products
exposure hazard and can penetrate the body.

. Other 1
> X-Ray radiation, which is also photon radiation, Total 361 90-1080

although x-rays originate from outside the nucleus. "National Council on Radiation Protection, 1987
X-rays are slightly lower in energy than gamma ? Hutlert, A.M., et al, 1994; Fisher, Eugene.

radiation and are the single largest source of
manmade radiation exposure.

Guide Overview

This guide is intended for regulators, technical assistance providers, and field staff helping drinking water systems
protect the public from exposure to excessive levels of regulated radionuclides in drinking water through the use of
treatment technology, and their staffs from exposure to radioactive wastes generated by treatment. It focuses
primarily on treatment for radium and uranium, the most common naturally-occurring regulated radionuclides. This
guide provides

1, Information on how systems can determine whether installing additional or new treatment technologies is
the best option for addressing radionuclides in source water, taking into account the residuals produced,
disposal options, and required operator skill level.

i)

Descriptions of the different treatment options listed by the U.S. Environmental Protection Agency (U.S.
EPA) as Best Available Technologies (BATs) and Small System Compliance Technologies (SSCTs).'

‘Oak Ridge Reservation, 2000. p. G-5

SBATS are the best technologies, treatment techniques, or other means that the U.S. EPA admunustrator determines to be available,
after examination for efficacy under field conditions and not solely under laboratory conditions (taking cost into consideration).
CTs are technologies that have been federally approved for systems serving fewer than 10,000 persons to use in complying with

2


L-D.3.2 Options for Disposal of Liquid Residuals

The options discussed below may be used for the disposal of liquid residuals including brines, concentrates, rinse
waters, backwash waters, acid neutralization waters, spent filter backwash water, filter-to-waste waters, supernatants,
and liquids from dewatering. A system’s options will depend on state regulations, the characteristics of the waste, and
cost-effectiveness. System location can also affect options; rural systems not located near a receiving body or POTW
may have to bulk transport liquid wastes for disposal (which may present additional problems, as systems transporting
over 270 pCi/g of uranium or 2,700 pCi/g of radium may be subject to DOT's radioactive material transport
regulations). States should consult with the appropriate program contacts to discuss which of these options (or any
alternative options) are available. See Appendix D for contact information, Decision Trees 2 and 3 for an overview of
the decision making process for systems that generate liquid residuals, and Section [II-B for information on
intermediate processing methods for residuals.

LD.3.2.1 Direct Discharge

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 must obtain a
National Pollutant Discharge Elimination System (NPDES) permit from the authorized state or U.S. 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 may include other provisions that protect water quality and
public health.

Federal water quality criteria and standards regulations do not set specific limits on radionuclides in discharges. States
have the authority to set criteria, standards and derived NPDES limits, and enforce them through permits. In
addition, state anti-degradation policies are also designed to protect the quality of certain water bodies and source
water protection efforts might restrict the levels of radionuclides in discharged waste. NRC regulations also restrict
licensees from releasing effluents containing radionuclides to the general environment (10 CFR 20.1301 to 1302). The
BATs and SSCTs listed in the Radionuclides Rule also remove co-occurring contaminants for which NPDES
regulations set limits; this could potentally further restrict a system’s options.

LD.3.2.2 Discharge to Publicly Owned Treatment Works

Drinking water systems may be able to discharge liquid wastes to a POTW indirectly through sanitary sewers or force
mains or by transporting the waste directly to the POTW. In most cases ‘stems are not required to obtain a
NPDES permit, but must ensure that their wastes meet the general and specific prohibitions of the Pretreatment
Program and any Technically Based Local Limits (TBI.Ls) that may be established by the state or by the POTW itself.
TBLLs should ensure that the POTW systems meet federal (40 CFR 403), state, and local pretreatment regulations,
and prevent the discharge of any waste that would interfere with or pass through the POTW treatment process and
cause a violation of the POTW’s NPDES permit, or inhibit recycling or reuse of the POTW's biosolids.
Municipalities (POTW owners) can refuse to accept waste that might trigger these events, and they generally have the
legal authority to refuse any wastewater that may pose other disposal problems for the POTW. Refer to Interagency
Steering Committee on Radiation Standards (ISCORS’) Assessment on Radioactivity in Semage Sludge: Recommendations on
Management of Radioactive Materials in Sewage Sludge and Ash at Publicly Onned Treatment Works for more information on
POTW legal and regulatory authority, and for guidance on identifying circumstances where discharge of liquid
residuals to a POTW may interfere with sewage sludge management practices or may pose a potential worker or
general public exposure concern.

uch s}

Arrangements between POTWs and systems may be enforced and conditioned by a local permit issued to the system
or through a contract, depending on federal, state, and local regulations. U.S. EPA regulations on the use and disposal
of the sewage sludge produced by POTWs (40 CFR 257 and 503) currently do not cover radioactive material. States
should encourage systems to contact the state NPDES program and potential receiving POTW, prior to choosing

18


816R05004

a A
@EPA A Regulators’ Guide to the
United States Management of Radioactive
Environmental Protection . .
Agency Residuals from Drinking Water

Treatment Technologies



Appendix B: References
AWWA, 1999, Water Quality and Treatment. New York, NY: McGraw Hill, Inc.

Bennett, D.L. 1978. “The Efficiency of Water Treatment Processes in Radium Removal.” Journal AWWA 70(12):
698-701.

Brink, W.L., R.J. Schliekelman, D.L. Bennett, C.R. Bell, and 1.M. Markwood. 1978. “Radium Removal Efficiencies in
Water Treatment Processes.” Journal AWWA 70(1): 31-35.

Clifford, D.A., W. Vijjesworapu, and S, Subramonian. 1988. “Evaluating Various Adsorbents and Membranes for
Removing Radium From Groundwater.” Journal AWWA 80(7):94.

Final Reports ISCORS: Assessment of Radioactivity in Sewage Sludge: Modeling to Assess Radiation Doses, ISCORS 2005-03,
NRC NUREG-1783, EPA 832-E-002A, DOK/EH -0670.

FinalReport: ISCORS Assessment of Radioactivity in Semage Sludge: Recommendations on Management of Radioactare Materials in
Senrage Sludge and Ash at Publicly Owned Treatment Works. ISCORS 2004-04, EPA 832-R-03-002B, DOE/EH-0068.

Fisher, Eugene, U.S. EPA Office of Radiation and Indoor Air, Personal Communication with authors of ISCORS
Draft Report.

Hanson, S., D. Wilson, and N. Gunaji. 1987. “Removal of Uranium from Drinking Water by lon Exchange and
Chemical Clarification.” EPA/600/S2-87/076.

Huffert, A.M. R.A. Meck, and K.M: Miller. 1994. Background as a Residual Radtoactivity Criterion for Decomissianing. Rep.
NUREG-1501. U.S. Nuclear Regulatory Commission.

International Atomic Energy Agency (IAEA). 9 January 2004. Technical Report Series. Report 419. “Extent of
Environmental Contamination from Naturally Occurring Radioactive Material (NORM) and Technological

Options for Mitigation.” Vienna, Austria.

International Commission on Radiological Protection (ICRP). “Protection Against Radon-222 at Home and at Work.”
ICRP Publication 65. Annals of the ICRP 23(2). Oxford, UK: Pergamon Press.

Lassovszky, P. and Hathaway, S. May 24-28, 1983. “Treatment Technologies to Remove Radionuclides from Drinking
Water.” Pre-conference Report for the National Workshop on Radioactivity in Drinking Water. Easton, MD.

National Academy of Sciences (NAS). 1999. Evaluation of Guidelines for Exposures to Technologically Etnhanced Naturally
Occurring Radioactive Materials. Washington, D.C.: National Academies Press.

National Council on Radiation Protection, 1987. lonizing Radtation Exposure of the Population of the United States. NCRP
Report No. 93. Bethesda, MD.

Nuclear Regulatory Commission and U.S. EPA. 1987. “Guidance on the Definition and Identification of Commercial
Mixed Low-Level Radioactive and Hazardous Waste.”

Oak Ridge Reservation. 2000. Annual Site Environmental Report.

Peterson, K. 1999, “Radionuclides Remoyal with Optimized Iron/Manganese Filtration.” Minnesota Department of
Health.


I-B Choosing the Right Technology: An Overview of Listed Best Available
Technologies and Small System Compliance Technologies

In promulgating the Radionuclides Rule, U.S. EPA listed BATs and SSCTs for removal of radionuclides from
drinking water. Although a system can use any means available (if allowed by the state’) to achieve compliance, this
guide focuses on the BATs and SSCTs that were listed by U.S. EPA on the basis of their efficacy and affordability in
the removal of radionuclides from drinking water. If a system chooses to install new or additional treatment, several
key factors should be considered.

Option Considerations

Installing New | + Will the treatment technology be effective in removing radionuclides given the source water
of Additional characteristics? Refer to the detailed treatment technology descriptions in Section II beginning on
Treatment page 27 of this guide for more information.

> Will the technology be efficient at removing co-occurring contaminants, helping the system comply
with other drinking water standards

>» — Is the treatment type suitable for the system’s size?

> — Is the operator appropriately trained to operate and maintain the chosen technology?

> Can pilot testing be performed to ensure the suitability of the technology?

> Does the system have or can it raise or borrow the funds needed to cover the capital and operation
and maintenance costs involved in installing and maintaining the treatment, including disposal costs?

> What residuals will be produced and can the system properly dispose of the residuals?

+ Are there additional costs associated with the disposal of wastes generated by the technology selected?

> Will the treatment process or residuals generated pose a radiation hazard to workers or result in the
need for the state radiation control agency to license the system?

In choosing a treatment technology, systems should also keep in mind that the characteristics of, and contaminant
concentrations in the residuals will help to define a system’s disposal options. The characteristics and contaminant
concentrations will vary according to:

> The concentration of radionuclides in the source water.

> How efficient the treatment is at removing radionuclides.

> Frequency of regeneration (for ion exchange [TX] and activated alumina [AAJ).
Frequency of filter backwash (for treatment methods using granular media filters).
» Frequency of IX resin, AA media, granular filter media, or membrane replacement.
> Loading to the treatment unit.

Tf possible, systems should conduct pilot tests of the treatment technologies to determine, for example, the
regeneration schedule that is most appropriate when using IX, or the frequency with which filters should be
backwashed. Pilot tests are a good way to determine whether system operators will have the time and skill to handle
the technology or whether a less complex option is more appropriate.

Table 3 on the following page outlines the treatment capabilities and applicability of the BATs and SSCTs listed in the
Radionuclides Rule. It also lists the level of operator skill required to operate and maintain the technology, For
additional information on each technology including removal efficiencies, see Section IT and Appendix E of this guide.

SNote that “state” refers to the Drinking Water Primacy Agency and/or the Underground Injection Control (UIC) Pumacy Agency.
5


Section I: Overview of the Removal of Radionuclides from Drinking Water

I-A Determining Whether Additional Treatment is Appropriate: Compliance
Options Overview

Installing a new treatment technology requires an investment of both time and money. There are several alternative
compliance options that may be more appropriate for some systems. Each option has its own n considerations that
should be weighed against a system’s particular circumstances.

Option Considerations
Developing a | > Are there other sources available that will produce water that complies with all regulations?
New Source » Will the new source meet demand?

> Is the new source close enough to the system to economically justify using it?

Blending Source | > Are there other sources available with radionuclide levels below the MCLs that can be blended with
Waters existing sources?

» — Is it economically feasible to blend sources?

» — Is it possible to blend the sources so that the MCLs are met at every entry point to the distribution
system and all required plant flow rates are maintained?

> If the system uses more than one problematic source, would abandoning any one source reduce the
radionuclide concentrations?

Connecting With | > _ Is there a nearby system meeting the requirements of the Radionuchdes Rule that is willing to
a Nearby System interconnect?

> Is it economically feasible to connect to the nearby system?

» Can the nearby system handle the increased demand of additional customers?

Optimizing | + Has the system attempted to optimize existing treatment?
Existing » Is the system currently using a technology approved as a BAT or SSCT for radionuchde removal?
Treatment > Isat possible to treat the source water to precipitate competing ions for increased radionuclide
removal?

If a system determines that the above options are not feasible, installing new or additional treatment may be the most
suitable and cost-effective means of complying with the Radionuclides Rule.


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Direct discharge - Discharges from point sources into surface water pursuant to a CWA NPDES permit facility.°

Free liquids - Liquids that readily separate from the solid portion of a waste under ambient temperature and pressure
(40 CFR 261.10).

Gamma (or X-ray) radiation - Also known as photon radiation, the high-energy portion of the electromagnetic
spectrum. The most penetrating type of radiation, capable of passing through the human body and common
construction materials. Gamma radiation is emitted during the decay of thorium and uranium.

Gross alpha particle activity - The total radioactivity due to alpha particle emission as inferred from measurements
ona dry sample.” (Net alpha is this same measurement minus uranium activity.)

Hazardous waste - Hazardous waste 1s defined under 40 CFR 261.3. Waste is considered hazardous if it 1s a solid
waste (as defined under 40 CFR 261.2) that is not excluded from regulation as hazardous waste under 40 CFR
261.4(b) and when it meets the criteria listed under 40 CFR 261.3(a)(2) and (b). The regulations most likely to be
applicable to TENORM waste are the hazardous waste characteristics, especially the toxicity characteristic (40 CFR
261.24).

Industrial waste - Unwanted materials from an industrial operation m the form of liquid, sludge, solid, or hazardous
waste.”

Tonizing radiation - Radiation that has sufficient enetgy to strip electrons from an atom.

Land disposal restrictions - Rules that require hazardous wastes to be treated before disposal on land to destroy or
immobilize hazardous constituents that might migrate into soil and ground water.*

Landfill - An area of land or an excavation in which wastes are placed for permanent disposal, and that is not a land
application unit, surface impoundment, or waste pile (40 CFR 257.2).

Large capacity septic systems - Septic systems that have the capacity to serve twenty or more persons per day.

Large Quantity Generators - Facilities that generate more than 1,000 kg of hazardous waste per calendar
month, or more than 1 kg of acutely hazardous waste per calendar month.”

Low-level radioactive waste - Radioactive waste not classified as high-level radioactive waste, transuranic waste,
spent nuclear fuel, or byproduct material as defined in the Atomic Energy Act section 11e.(2) (uranium or thorium
mill tailings and waste).

Maximum Contaminant Level - The maximum permissible level of a contaminant in water which is delivered to any
regulated uset of a public water system (40 CFR 141.2).

“US. EPA, January 2003,
“US. EPA, 1994a,
“US. EPA, 1997.

SUS. E

A, 1997,

“U.S. EPA, January 2003.


In circumstances where a facility may in the future be licensed by the NRC or Agreement State, worker safety
precautions and radiation protection controls would take precedence (e.g., 10 CFR 20.1900, which lists radiation
exposure posting requirements).

In addition to the OSHA requirements, systems should be encouraged to follow the safety practices listed below.
These measures can reduce workers’ risk of exposure to radioactivity and radioactive particulates:

Safety Measures

Y Use an OSHA-approved respirator to avoid inhalation of biological pathogens and chemically toxic materials in
residuals, Simple dust masks may not provide adequate protection.

¥ Limit time spent at land disposal sites to reduce inhalation of contaminated dust.
7 Ventilate all buildings, especially where waste with high concentrations of radium is stored.

Y — Take standard OSHA measures to limit the potential ingestion of heavy metals and biological pathogens present in
filters, residual sludges, and at land disposal sites to help reduce possible ingestion exposure to radioactive materials.

VY Use protective gloves and frequently wash hands (particularly before eating and drinking) to reduce the potential for
ingestion. Similarly, avord eating and drinking in the vicinity of facihties or land disposal sites where air suspension of
contaminated particulates or water droplets could occur.

Y Avoid direct contact with any solid TENORM waste and use shovels or other remote-handling tools during extraction,
transfer, and packaging,

Y Locate treatment units and waste storage areas as far away from common areas (€.g., offices) as possible.
Y Shower after exposure to potentially radioactive materials and 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 or shoes should be wiped and cleaned after potential contamination.
They should stay at the system or not be worn into the home.

ise gamma survey instruments or equivalent monitors at least once annually to monitor the system’s ambient radiation

levels in areas where radionuclides are removed.

wv — 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.

Treatment plants that are licensed by the NRC or Agreement State should be referred to CFR Parts 19 and 20 for
licensee reporting, notification, inspection, and safety requirements. Licensed facilities are required to post the
regulations listed under Parts 19 and 20, along with numerous other documents related to the license and the activities
conducted under the license. Employees likely to receive occupational doses greater than 100 mrem/year must be
kept informed and instructed on various issues related to health protection, relevant regulations, and the facility’s
storage and transport of radioactive materials, among other things. Licensees must also keep individual employees
informed of the annual radiation dose that they receive. Current and former employees can also request reports on
their exposure to radiation or radioactive material.

10 CFR Part 20 outlines requirements for licensees to develop radiation protection programs (10 CFR 20.1101), sets
dose limits and occupational limits for exposure to radiation (10 CFR 20.1201 to 1302), instructs licensees on how to

25


Peterson, K. June 11-15, 2000. “Radionuclides Removal with Optimized Iron/Manganese Filtration.” Presented at
AWWA Conference. Denver, CO.

Reid, G.W. et al. May 1985. “Treatment, Waste Management and Cost of Radioactivity Removal from Drinking
Water.” Health Physics Journal, Vol. 48.

Schlickelman, R. June 1976. “Determination of Radium Removal Efficiencies in Illinois Water Supply Treatment
Processes.” U.S. EPA Technical Note. ORP/TAD-76-2.

Snoeyink, V., et al. 1984. “Characteristics and Handling of Wastes from Groundwater Treatment Systems.” Seminar
on Experiences with Groundwater Contamination. AWWA National Conference.

Sorg, T. April 1980. “Removal of Radium-226 from Drinking Water by Reverse Osmosis in Sarasota County, Florida.”
Journal AWWA.

Sorg, T. 1988. “Methods for Removing Uranium from Drinking Water.” Journal AWWA 80(7).

Sorg, T. 1990. “Removal of Uranium from Drinking Water by Conventional Treatment Methods,” in Radon, Radium,
and Uranium in Drinking Water. C. Richard Cothern with Paul A. Rebers. Chelsea, MI: Lewis Publishers.

‘Tonka Equipment Company. Radinm Remoral from Potable Water. Tonka Technical Bulletin.
bup:// won tonkaw ater.coms whatsnew /pdf/ RadiumRemorallech Bulletn.pdt

U.S. Department of Energy. 1994. “Appendix C - Glossary.” In: Committed to Results: DOE's Environmental Management
Program, An Introduction (EM Primer). DOE/EM-0152P.

US. Department of Energy. 1997. “Applying the ALARA Process for Radiation Protection of the Public and
Compliance with 10 CFR Part 834 and DOE 5400.5 ALARA Program Requirements,” Volume 1, Draft.

U.S. Department of Energy and U.S. EPA Interagency Steering Committee on Radiation Standards (ISCORS). 2003.
Assessment on Radioactivity in Sewage Sludge: Recommendations for Management of Radioactive Materials in Senage Sludge and
Ash at Publicly Onned Treatment W “orks. Draft Report. DOE-EH-0668, EPA 832-R-03-002B.

U.S. EPA. Date unknown. Land Disposal Restrictions Glossary.
hup:/ wv ww.cpa. guys cpaoswer/haywasic/ldr/ glossary him

US. EPA. Date unknown. Mixed Waste Glossary.
hop! ‘www epigor radiation /mised waste /imw_pg5.hen

US. EPA. Date unknown. SW-846 Manual. “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods.”

U.S, EPA. 1977. “Manual of Treatment Techniques for Meeting the Interim Primary Drinking Water Regulations.”
EPA 600/8-77-005.

US. EPA. 1981. Radfoactirity in Drinking Water. Health Effects Branch, Criteria and Standards Division, Office of
Drinking Water. EPA 570/9-81-002.

US. EPA. 1982. “Disposal of Radium-Barium Sulfate Sludge From a Water Treatment Plant in Midland, South
Dakota.” Technical Assistance Program Report prepared by Fred C. Hart Associates, Inc. for U.S. EPA Region 8.

US. EPA. 1986. “Technology and Costs for Treatment and Disposal of Waste Byproducts by Water Treatment for
Removal of Inorganic and Radioactive Contaminants.”

B-2


Pathway Concern

Ingestion Ingestion, or the swallowing of alpha, beta, or gamma-emitting radioactive materials, 1s a
concern for the same reasons as inhalation exposure. Workers can ingest radioactive
materials if they fail to observe good sanitary practices including washing their hands before
cating; failing to cover their noses and mouths by wearing approved respiratory protection
and swallowing contaminated dusts and water droplets; or eating and drinking in areas
(including land disposal sites), where dusts or water droplets could settle on food or drink.
Simple dust masks may not provide adequate protection from exposures via this pathway.

Direct Exposure | Radioactive materials that emit gamma radiation are of 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. As gamma radiation travels through air,
exposure can occur near a source of radiation as well as through direct contact. Workers
most likely to be directly exposed are those who handle or work in the vicinity of resin tanks,
residuals, filter backwash, and contaminated brines or waters, or participate in the
maintenance of the treatment system or the replacement and transportation of filter media.

The International Commission on Radiological Protection (ICRP) and National Council on Radiation Protection and
Measurements (NCRP) have recommended that facilities strive to make the levels of radiation to which the public and
the environment are exposed as low as reasonably achievable (ALARA) (i.¢., below regulatory limits) taking into
account social and economic considerations. Steps that facilities can take include limiting the time that workers spend
handling radioactive material, increasing the distance between workers and the material, and providing shielding from
the radioactive material.

In addition, OSHA has developed occupational radiation standards (see 29 CFR 1910.1096) that might apply
whenever an operator becomes aware of the presence of radiation at the facility. Although these standards may not
apply to municipal water treatment plant workers, these workers may be covered by their state OSHA program,
requiring that all controls, monitoring, record keeping, and training outlined in the OSHA standards be met.

Additional OSHA standards that may be applicable to water systems include:

> Requirements that personal protection equipment (or 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 through absorption, inhalation, or
physical contact necessitate such equipment. There are numerous other requirements related to the
possession and use of PPE, including training for employees who would use the equipment. For more
information, see 29 CFR 1910.132-136.

» — Requirements for practices and procedures to protect employees in general industry from the hazards of entry
into permit-required confined spaces. For more information, see 29 CFR 1910.146.

» Lockout/tagout requirements that require employers to establish a program and follow procedures for
affixing appropriate lockuut or tagout devices to energy isolating devices and disable machines or equipment.
This avoids injury to employees by preventing unexpected energization, start-up, ot release of stored energy.
For more information, see 29 CFR 1910.147.

» Hazardous communication requirements that ensure the potential hazards of chemicals produced during or
imported for treatment are evaluated and the information from this evaluation is communicated to employees
through measures such as container labeling, material data safety sheets, and employee training, among others.
These requirements do not apply to RCRA-defined hazardous waste or ionizing or non-ionizing radiation.
For more information, see 29 CFR 1910.1200.

24


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Introduction

The Radionuclides Rule

Community water systems (CWSs) were required to begin
complying with the revised Radionuclides Rule on December 8,
2003. The Rule retained the maximum contaminant levels (MCLs)
for combined radium-226/228, gross alpha particle activity, and
beta particle and photon radioactivity. The Rule also revised and
added to existing requirements, set a new MCL for uranium! and
separate monitoring requirements for radium-228, and required
CWSs to monitor at each entry point to the distribution system.
For more information on the Rule’s requirements, see:

i ml.

adionuc.

bup Avy cpasor WW ail

Public Health Risks of Exposure to Radionuclides in
Drinking Water

Radiation exposure is regulated on the assumption that any
exposure carries some risk of a health effect. Radiation-induced
health effects can be deterministic, in which biological damage is
readily observed and proportional to the level of exposure, or
stochastic, in which the probability of a health effect is related to the
level of exposure, but the severity is not. Deterministic effects

Table 1: Radionuclides MCLs

Combined radium-226 and 228 5 pCi/L

Gross alpha particle activity
(excluding radon and urantum)

15 pQi/L

Beta particle and photon 4 mrem/vear

radioactivity

Uranium 30 pg/L

Measuring Radiation

Quantities of radioactive material are measured as
radioactivity or activity in curies, 1.c.,
disintegrations (decays) per second. The potential
for health hazards increases as activity increases.
Radioactive material found in water treatment plant

residuals or source water is usually measured in
microcuries or picocuries (pCi).

have only been observed at relatively high exposures delivered
over a short time. Doses associated with exposures to natural
background radiation or typical radioactive materials in water
treatment plants are generally many times lower than the high
doses that are needed to cause such effects. Stochastic effects are
more typical of low radiation doses, often delivered over a period
of time (e.g,, chronic exposures). The principal concern associated

The body’s exposure to 1onizing radiation 1s
typically expressed in millirem (mrem). Dose
standards are typically expressed as a rate of
exposure, in millirems per unit of time (¢.g,, hours
or years).

with low dose radiation exposure is the possible occurrence of
cancer years after the exposure occurs. In addition, uranium can
be chemically toxic to the kidneys.

Fundamentals of Radiation

Human beings are constantly exposed to radiation ftom natural and manmade sources. The average radiation dose to
an individual in the United States is about 360 mrem/yr (see Table 2 on the following page). On average, 80 percent
of that exposure comes from natural sources including cosmic radiation from outer space; terrestrial radiation from
natural radioactive materials in rocks, soil, and minerals; and radiation inhaled or ingested from food and water.”
Additional exposure comes from manmade sources of radiation including medical X-rays and industrial use of
radioactive material. Table 2 on the following page summarizes average annual exposures to radiation within the
United States. Note that radiation exposure can vary greatly according to factors such as an individual’s location,
lifestyle, and daily activities.

Radiation 1s characterized as “ionizing” and “non-ionizing.” Uranium and radium occur naturally in rocks and soil as
the result of radioactive decay, or the release or transfer of excess energy, of uranium-238 and thorium-232. This
excess energy is 1onizing radiation. Ionizing radiation is of sufficient energy to break chemical bonds and remove
electrons, potentially causing biological damage. Non-tonizing radiation, such as visible light and infrared, is lower

‘“Urantum” refers to all isotopes that make up naturally occurring uranium: U-238, U-235, and U-234,

°U.S. Department of Energy and U.S. EPA Interagency Steering Committee on Radiation Standards (SCORS), 2003-004
1


3.1.1 Testing for Free Liquids

Systems must perform the Paint Filter Liquids Test (or PFLT; EPA SW 846 Method 9095) to determine if the waste
contains any “free liquids” because solid waste landfills cannot accept waste that contains free liquids. If free liquids
are present, the system will need to employ an intermediate processing method and determine an appropriate method
of disposal for the liquid residuals generated by dewatering. (See Section II-B of this guide, “Intermediate
Processing,” for more information.)

LD.3.1.2 Testing for Radionuclides

There is no federal requirement to test waste residuals specifically for radionuclides, and no specific federal regulation
governing landfill disposal of water treatment plant solids or sludges containing TENORM. However, systems must
comply with mote general requirements applicable to the disposal of solid waste.

It is the responsibility of the individual states to determine the most appropriate analytical method for testing water
treatment plant waste containing TENORM (and possibly source material) and any requirements or guidelines for
posal. If allowed by the state, systems can use the NRC/U.S. EPA “Guidance on the Definition and Identification
of Commercial Mixed Low-Level Radioactive and Hazardous Waste” (available at

htepsd diation/mixed-waste/mw_pe25.hen). If licensable concentrations of source material are
found at systems in non-Agreement States, the appropriate NRC regional office should be consulted (see

Appendix D).

Wepa. vow!

U.S. EPA and other federal agencies have also developed the Multi-Agency Radiological Laboratory Analytcal
Protocols Manual (MARLAP), which addresses the need for a consistent national approach to producing
radioanalytical laboratory data that meet a project’s or program’s data requirements. The manual provides guidance
for the planning, implementation, and assessment phases of projects that require the laboratory analysis of
radionuclides and is available on U.S. EPA’s Web site at herp

yew. cpa.gow/ radiation/marlap.

States should consult with radiation program staff for more information (see Appendix D), and can also refer to U.S.
EPA’s list of approved analytical methods at btep:

www epa.gor /safers atermethods/methods.hurl,

LD.

Choosing an Appropriate Landfill

There are several types of landfills that may provide protective disposal for residuals containing radionuclides. The
appropriate landfill can depend on the amount, concentration, and physical and chemical attributes of the
radiologically-contaminated material, the mobility of radionuclides and their decay products, the consideration of
future controls and future land use, and state and local regulauons.

1-D.3.1.3.1 Solid waste landfills

Municipal solid waste landfills may have restrictions on the amount of radioactivity they accept. Their ability to accept
specific wastes should therefore be verified. These landfills may accept non-hazardous, solid, and TENORM wastes
from all water systems, and hazardous waste from Conditionally Exempt Small Quantity Generators (see the MSWLP
requirements at 40 CFR 258 and the information on hazardous waste on page 11 of this guide). Industrial solid waste
landfills may also accept non-hazardous solid TENORM waste, and may be better equipped to handle such waste as it
is more like the waste that industrial landfills typically handle (¢.g., sludges and ash).

As they become more aware of issues surrounding disposal of radioactive materials, more landfills are now using
monitors to scan incoming trucks for radiation. In some cases, wastes that had previously been accepted were found
to contain elevated levels of TENORM. If the monitors are triggered, the source must be identified and evaluated. A
list of municipal solid waste landfills (for non-hazardous waste) can be found at

bitpy/ ww cpa.vor/epaoswer/non-hw /munepl/land fill section3.pdf.

15


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Table 14: Pre-formed Hydrous Manganese Oxide (HMO) Filtration Overview

Use

SSCT Listed as a SSCT for radium removal for systems serving 25-10,000 customers

Radium removal efficiency depends on the levels of HMO added during the treatment process; removal
efficiencies of up to 90% may be achieved”*

Ligmd Spent filter backwash water (contains radium, particulates, and any co-occurring
contaminants)
Residuals
Solid Spent filter media (contains moderate concentrations of radium and any co-occurring
contaminants) and sludge
» — Operators should determine the appropriate dosage of HMO, taking source water characteristics into
consideration
ae >» — If source water iron levels are high, oxidation can enhance tron removal through filtration; if iron.
Limitations - ~
coatings form on the filter, radium can be desorbed
> HMO treatment installation may be prohibitively expensive for systems that do not already have a
filtration system
Table 15: AA Overview
Use SSCT Lasted as a SSCT for uranium removal for systems serving 25-10,000 customers
Efficiency | AA may remove up to 99% of urantum in drinking water”
Liquid Spent brine (volume varies according to raw water quality, unit size, regenerant concentration
Residuals and media capacity), rinse water, backwash, and acid neutralization
Sold Spent media
Additional Direct > Normally not an option due to high TDS levels and high contaminant concentrations
4 dischae |» Blending brine with backwash, rinse, and acid neutralization waters can significantly
Disposal i ig
* reduce radionuclide concentrations and TDS
Issues’ a . aa
+ Additional pretreatment may be required in addition to flow equalization
Limitations | + AA has a higher affinity for other contaminants, such as arsenate, fluoride, and sulfate

> The technology is very pH sensitive and the handling of chemicals required for pH adjustment (to
increase uranium removal) and regeneration necessitates having a highly skilled system operator

> — Successful operation may require monitoring effluent pH to establish accurate breakthrough curves

> Special disposal procedures may be required for media that can no longer be regenerated, parucularly if
the media has not been regenerated before removal

* All of the common disposal considerations in ‘Table 7 must also be taken into account.

“Tonka Equipment Company, date unknown.

© Sorg, T., 1988.

* AWWA, 1999,



Appendix G: Additional Reference Materials

The following resources provide more information on the Radionuclides Rule, and the treatment, handling, and
disposal of radionuclides:

Documents

Evaluation of EPA's Guidelines for Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM), Report to
Congress, EPA 402-R-00-01, June 2000

(htepe/ few agor / radiations tenorm/docs/

as_renp.palf)

Evaluation of Guidelines for Exposures to Technologically Enhanced Naturally Occurring Radioactive Materials, Committee on
Evaluation of EPA Guidelines for Exposure to Naturally Occurring Radioactive Materials, National Academy of
Sciences, 1999

(hup:/ Aw. 8 nap.cdu/ books /0309062977/ hun Andes. hum)

Final Report: ISCORS Assessment of Radioactivity in Sewage Sludge: Radiological Survey Results and Analysis, NUREG-1775,
EPA 832-R-03-002/DOE/EH-0669, November 2003
(dup: fw w

scors.org/ LinalSurves pa)

Implementation Guidance for Radionuclides, EP A 816-F-00-002, March 2002
(beep: / Awww epawov/safewater/rads/ final rads implementayon vuidance pdt)

Radioactive Material Regulations Overview, U.S. Department of Transportation, Research and Special Programs
Administration
(beep! haymat dot.gov/pubrrain /ramreview.pdt)

Radionuclides Rule (Final), Federal Register, Vol. 65, No. 36, December 7, 2000

(htep:/ “www epagov/safewarer/rads/radirpdf)

Radionuclides Rule: A Quick Reference Guide, EPA 816-F-01-003, June 2001
(otrpy/ awww. pa gous

ads /quickwuide.pdf)

Radionuclides in Drinking Water: A Small Entity Compliance Guide, EPA 815-R-02-001, February 2002
(htrp:/ Awe w.cpa.uor /safewater/rads/ pdfs /rads-smallsvscompynide.pdt)

Radionuclides Notice of Data Availability, Technical Support Document, EPA, March 2000
(bitp-/ www epayov/satewarer/rads/tsd.pdf)

RCRA Orientation Manual, EPA 530-R-02-016, January 2003

(hippy! Awwwepa.gov/ cpaoswers sencral/ orentat/ 120 16.pdf)

Web sites

Conference of Radiation Control Program Directors, Inc. - htep:/ /www erepd.ore

U.S. EPA Office of Air and Radiation.
Radiation Protection - hitp://wawepagov /ra
Managing Radioactive Materials and Waste - hitp:/

on /index hel

wow gousradunor Aenorm /index.huml *

G-1


Table 16: Coagulation/Filtration Overview

Use BAT Listed as a BAT for uranium removal
SSCT | Listed as a SSCT for uranium removal for systems serving 25-10,000 customers
> The efficiency of uranium removal depends on water pH, the prevailing charge on the floc, and the types
. and amount of uranium present in the water
Efficiency ' num present in . - 9
> Uranium removal efficiencies of 85% to 95% have been observed at pH levels of 6.0 and 10.0"
» See also Appendix F, Table E-1
Liqud | Spent filter backwash water and filter-to-waste (if practiced)
Residuals
Sold Sludge and spent filter media
Additional Direct Blending brine with backwash water can significantly reduce radionuclide concentrations and
Disposal discharge | TDS
Issues*
Limitations |» ‘The use of this technology for uranium removal 1s only practical if the system has coagulation /filtration
in place and can modify the existing processes to optimize uranium removal
> Choosing the most surtable coagulant for a system requires an understanding of source water
characteristics, especially pH. The choice of coagulants will affect the characteristics of the residuals
produced during treatment.
+ Using this technology necessitates having a highly skilled system operator

*All of the common disposal considerations in Table 7 must also be taken into account.

"U.S. EPA, 1992.

33



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Executive Summary

The revised Radionuclides Rule came into effect on December 8, 2003. U.S. EPA’s revisions to the Rule provide
standards that, if met, ensure that all customers served by community water systems (CWSs) receive water that meets
the Maximum Contaminant Levels (MCLs) for radionuclides in drinking water. Regulated radionuclides include
tadium-226, radium-228, gross alpha particle activity, uranium, and beta particle and photon radioactivity.

In accordance with the Rule, all CWSs must complete initial compliance monitoring by December 8, 2007. While
most systems will be in compliance with the revised Rule, systems in areas of the country with elevated levels of
naturally occurring radionuclides, and the few systems located near facilities that could potentially contaminate source
waters with radioactive substances, might have to install new or upgrade existing treatment to meet these revised
standards. These treatment processes will produce residuals contaming regulated radionuclides.

This guide is intended for state regulators, technical assistance providers, and field staff. It is designed to help states
address radionuclide residual disposal by outlining options available to help systems address elevated radionuclide
levels. It provides an overview of the types of treatment listed as Best Available Technologies (BATs) and Small
System Compliance Technologies (SSCTs) by U.S. EPA, the wastes produced by these technologies, waste disposal
options and considerations, and the federal statutes and regulations governing waste disposal. This guide, however, 1s
not intended to identify concentrations of radionuclides that are appropriate for each disposal option. As part of U.S.
EPA’s Advance Nouce of Proposed Rulemaking (ANPR) effort on low-activity waste (68 FR 65120, November 18,
2003), the Agency is evaluating the conditions under which various disposal options would be appropriate for
radioactive material (with a focus on hazardous waste landfills); that guidance is still applicable.

Some states have been grappling with the issue of radioactive residual disposal for some time, while others are just
beginning to address these waste disposal issues. Relevant state agencies and programs (¢.g., drinking water, radiation
control, solid waste) will benefit from coordinating with each other to determine appropriate disposal options. The
challenge for states is to find a balance between appropriate treatment technologies, safe waste disposal practices
worker safety, and cost, yet ensure compliance with the Radionuclides Rule and other drinking water regulations.
Note that this guide presents a generalized overview of residual management. Due to the variability in state
regulations, waste concentration and characteristics, and removal efficiencies associated with treatment technologies,
systems’ residual management responsibilities may be more extensive or complex than presented.

The federal statutes and regulations discussed in the guide set the minimum standards by which systems must operate.
States, however, have the authority to set more stringent standards. State treatment and waste disposal regulations
may, as a result, be stricter and significantly more complex than those presented in this guide. Systems should alwa
be reminded to check with their state before proceeding with treatment installation or modification and waste disposal
to ensure they are meeting all relevant federal, state, and local requirements.



Well - Any bored, drilled or driven shaft or dug hole whose depth is greater than the largest surface dimension; or an
improved sinkhole; or a subsurface fluid distribution system used to discharge fluids underground.

Well injection - The subsurface emplacement of fluids through a well.

A-5


Maximum Contaminant Level Goal - The maximum level of a contaminant in drinking water at which no known
or anticipated adverse effect on the health of persons would occur, and which allows an adequate margin of safety.
Maximum contaminant level goals are non-enforceable health goals."

Mixed waste - Radioactive waste that is also a hazardous waste under RCRA. These wastes are jointly regulated by
RCRA and the AEA.”

Municipal solid waste landfill - A discrete area of land or excavation that receives municipal solid waste.”

Non-ionizing radiation - Radiation that “bounces off or passes through matter without displacing electrons.” Its
effect on human health is undetermined. Sources of non-ionizing radiation include radios, microwaves, and infrared
light.

Paint Filter Liquids Test - Test to determine the presence of free liquids in a representative sample of waste, used to
determine compliance with 40 CFR 264.314, 265.314, and 258.28. A predetermined amount of material is placed in a
paint filter. If any portion of the material passes through and drops from the filter within the 5 minute test period, the
material is deemed to contain free liquids."

Publicly Owned Treatment Works - A treatment works as defined by section 212 of the CWA, which 1s owned by a
state or municipality (as defined by section 502(4) of the CWA). Included are any devices and systems used in the
storage, treatment, recycling and reclamation of municipal sewage or liquid industrial wastes. It also includes sewers,
pipes and other conveyances only if they convey wastewater to a POTW. This definition also includes the
municipality as defined in CWA section 502(4) that has jurisdiction over the indirect discharges to and the discharges
from the POTW. (40 CER 403.3(0))

Radiation - The emitting of energy through matter or space in the form of waves (rays or particles).”*
Radioactive decay - The spontaneous radioactive transformation of one nuclide (or isotope) into a different nuclide
or into a lower energy state of the same nuclide. Radionuclides decay principally by emission of alpha particles, beta

particles, and gamma rays.”

Radionuclide - Any man-made or natural element that emits ionizing radiation.

“US, EPA, 1994a,

“U.S, EPA, January 2003.

°US, EPA, January 2003.

“Oak Ridge Reservation, 2000, p. G-5

Shoup. www upeor/epaosn er hanwayedtecy pd 9095a pdt

DOE, 1994.

. DOE, 1994.

“US. EPA, 1991.
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The current version of SPAARC incorporates predictive algorithms to estimate radionuclides and co-contaminant
removals, and focuses on a sound estimate of residual radionuclides concentrations and co-occurring pollutants rather
than sizing and designing drinking water treatment technologies. It is a flexible and highly interactive tool requiring
minimum learning time and was developed as a stand-alone desktop application using state of the art software
development tools. The program allows the operator to select the type of treatment process, as well as input and
output parameters such as water flows, doses of coagulant and polymer, and filter capacities.

The current SPARRC model covers six technologies and associated co-contaminants including:

Technology Radionuclides Co-Contaminant
Coagulation Filtration Uranium Arsenic
Lime Softening Radium and Uranium None
IX Radium, Barium, and Uranium None
RO Radium and Uranium None
AA Urantum Arsenic
Green Sand Filtration Radium and Barum None

The current version of SPARRC is available at http://www npdespermits.com/sparre. For questions concerning the
model, contact Rajiv Khera at U.S. EPA's Office of Ground Water and Drinking Water at 202-564-4881 or
khera.rajiv@epa.gov.

The concentration of radionuclides in the waste stream, the type of waste produced, and federal and state regulations
are among the factors that dictate which disposal options ate available to a system, Treated water pH, total dissolved
solids (TDS), total suspended solids (TSS), and heavy metals concentrations in the waste stream can also limit disposal
options. Section I-D provides an overview of applicable federal regulations and the disposal options that may be
available to systems removing radionuclides from their source water.

“Version 1, July 2003. Note that this model ts a draft version for which U.S. EPA 1s still seeking comment and has not gone through
a peer review process.

8


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The Clean Water Act (CWA; 33 USC 1251 to 1387), under which U.S. EPA establishes requirements for
direct discharges of liquid waste or the discharge of a liquid waste to publicly owned treatment works

(POTW).

The Safe Drinking Water Act (SDWA; 42 USC 300f et seq.), which requires that U.S. EPA develop minimum
federal requirements for underground injection control (UIC) programs (state or primacy) to ensure that

underground injection does not endanger current and future underground sources of drinking water
(USDWs) (40 CFR 144-148).

The Atomic Energy Act of 1954, as amended (AEA; 42 USC 2011 et seq.), which requires the Nuclear
Regulatory Commission (NRC) to regulate the civilian commercial, industrial, academic, and medical use of
nuclear materials. The Act enables the NRC to relinquish some of its regulatory authority over source
materials to states through the signing of an agreement between the state’s Governor and the NRC
Chairperson. Currently, 33 states have entered such agreements and ate referred to as “Agreement States.”
Agreement States must establish radiation protection programs compatible with the NRC’s and the NRC
remains involved with state licensing, inspection, and rule changes, among other things. For more
information and a list of Agreement States, see http://

Department of Transportation (DOT) regulations (49 CFR 171 to 180), which govern the shipping, labeling,
and transport of hazardous (including radioactive) materials.'”

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, 42 USC 9605 et
seq.) National Oil and Hazardous Substances Pollution Contingency Plan (NCP, 40 CFR 300) applies to the
telease or threat of release of hazardous substances (including radionuclides) that many endanger human
health and the environment. If disposal of radionuclide-contaminated residuals results in a release or threat of
release that endangers human health or the environment, CERCLA may require cleanup of the hazardous
substance.

"In 49 CER 173.436, DOT provides levels for individual radionuclides (both in terms of concentration and a total consignment

“Hazardous Materials Regulauon
FR 3632, January 26, 2004, at au:p:/

.) that are exempt from the DOT requirements which would normally apply for transporting radioactive mater:

(See
ompaubility With the Regulations of the International Atomic Energy Agency; Final Rule,” 69
<pdi). In the preamble to the Rule, DOT explains that the

wigupecom, pdt oir 363

exemptions apply to “other natural materials or ores...when those materials or ores are to be used because of some other physical or
chemical characteristics...{or] when these have been subjected to physical or chemical processing, when the processing was not for the
purpose of extracting radionuchdes...provided that their radionuclide concentration does aot exceed 10 umes the activity
concentration in the table in [section] 173.436.”

‘To determine whether a system falls under the DOT radioactive material transport regulations, the svstem must determine the
radionuclide acuity concentrations and acuvities and calculate the effecuve exemption values (assuming that you have more than one

radionuclide).

fers can use “process knowledge” to aid in making these determinations. See Appendix C for additional

information,

10


Please note that the U.S. EPA statutes and regulations described in this document contain legally
binding requirements. This guidance document replaces all earlier U.S. EPA draft guidance documents
on radionuclides residual disposal for drinking water treatment. The recommendations in this
document are not substitutes for those statutes or regulations, nor is this document a regulation. This
guide is strictly voluntary, and does not impose legally-binding requirements on U.S. EPA, states, local
or tribal governments, or members of the public, and may not apply to a particular situation based
upon the circumstances. Although U.S. EPA recommends the approaches outlined in this document,
state and local decisionmakers are free to adopt approaches that differ from those presented in this
guide. Interested patties are free to raise questions about the appropriateness of the application of this
guide. Any U.S. EPA decisions regarding a particular water system or wastestream will be made based
on the applicable statutes and regulations. U.S. EPA will continue to review and update this guide as
appropriate.



Table 12; Co-precipitation with Barium Sulfate Overview

Use SSCT Listed as a SSCT for radium removal for systems serving 25-10,000 customers
Co-precipitation with barium sulfate (using a soluble barium salt such as barium chloride) has been shown to
Efficiency remove over 95'% of radium from mine wastewaters, and between 40% and 90% of radium from drinking
water”
Liquid | Spent filter backwash water (contains radium, particulates, and any co-occurring
contaminants)

Residuals Sohd Spent filter media (contains moderate concentrations of radium and any co-occurnng
contaminants) and high volumes of barium sulfate sludge (may contain high concentrations
of radium and any co-occurring contaminants)

+ This technology necessitates having a highly skilled operator

> — This technology is not widely used, It is more commonly used to remove radium from waste effluents

Limitations than from drinking water and 1s only effective for source waters with high sulfate levels.
> — This technology involves static mixing, detention basins, and filtration. It may not be practical for small
ems that do not already have in place suitable filtration to treat high sulfate levels.
Table 13: Electrodialysis /Electrodialysis Reversal Overview
Use SSCT Listed as a SSCT for radium removal for systems serving 25-10,000 customers; also effective
at removing uranium
Efficiency | See Appendix E, Table E-1
Ligmd | Concentrated waste stream
Residuals
Sod | Spent membranes
Limitations | Systems may have difficulty removing radionuclide build-up from the membrane, which could complicate

disposal

*Clifford, D.A., et al, 1988,

31



cnorm /index.huml

TENORM - hrip: aon

U.S. EPA Office of Ground Water and Drinking Water
Radionuclides in Drinking Water - https,
Underground Injection Control Program - brtp:/

awov/satewater/radeenuchent

/safewater/ uc html

AWwaw.c)

WWW. cpa.vov

U.S. EPA Office of Solid Waste and Emergency Response
Hazardous Waste Identification - herp:
Key Radiation Guidances and Reports - hup:/
Non-Hazardous Waste (RCRA Subtitle D) - herp:
Paint Filter Liquids Test - hrtp:/ “www cpa.gou/e

baawaste /id/indes htm

WW epagor /epaoswet

Avww cpa.gov/cerrpave/supertund/ resources / radiation, ‘index.him

WW cpa.gov/osw /

US. EPA Office of Wasterater Management
NPDES - hattp:/ /efpui ;

The TENORM Page - hrrp:/ www tenorm.com/

G2


discharge to a POTW as a disposal option to determine whether the system is capable of meeting the applicable local
limits, and to ensure that the wastes will be accepted.

Note that liquid wastes that are mixed with domestic sewage and discharged to a POTW are not regulated under
RCRA, because they are subject to the Clean Water Act. This exclusion from RCRA is commonly known as the
domestic sewage exclusion (§261.4(a)(1)).!° A hazardous waste that is accumulated, managed, or transported (e.g., by
truck) prior to introduction into the sewer system, however, would still be subject to regulation as a hazardous waste.
Encourage systems that believe their wastes to be hazardous to contact the appropriate state agency and local POTW
to ensure that wastes are properly managed.

Systems that exceed both the ‘unimportant quantity’ and ‘small quantity’ thresholds for uranium will normally be
specifically licensed by NRC or Agreement State; there are strict limits set by 10 CFR 20.2003 for disposal into any
sanitary sewer systems. Under these conditions: the material must be readily soluble (or readily dispersed biological
material) in water; the quantity of licensed or other radioactive material that is released into the sewer in one month,
divided by the average monthly volume of water released into the sewer, cannot exceed the concentration listed in
Table 3 of Appendix B in 10 CFR 20; and the total quantity of licensed and other radioactive material that the licensee
releases into the sanitary sewer in a year cannot exceed 5 curies (185 GBq) of hydrogen-3, 1 curie (37 GBq) of
carbon-14, and 1 cutie (37 GBq) of all other radioactive materials combined. Additional requirements apply if more
than one radionuclide is released. If the state has adopted naturally occurring radioactive material (NORM) or
TENORM regulations which apply to water treatment facilities, those regulations should be consulted to determine if
there are radionuclide discharge requirements to POTWs.

1-D.3.2.3 Underground Injection

U.S. EPA developed federal regulations under SDWA that address underground injection and protect underground
sources of drinking water. To determine which federal UIC regulations apply, systems will need to determine if their
waste is radioactive, hazardous, or nonhazardous. Under the UIC regulations, “radioactive” refers to any waste
containing radioactive concentrations that exceed those listed in 10 CFR 20, Appendix B, Table 2, Column 2. These
concentrations are 60 pCi/L for radium-226, 60 pCi/L for radium-228, and 300 pCi/L for uranium.

Note that the “unity rule” applies if there 1s more than one radionuclide involved. The “unity rule” sets the
concentration limit of each radionuclide such that the sum of the fractions contributed by each radionuclide does not
exceed 1, For example, in a material with 30 pCi/L of radium-226, 30 pCi/L of radium-228, and 150 pCi/L of
uranrum, the fraction contributed by radium-226 is 30/60 pCi/L, or 0.5; the fraction contributed by radium-228 is
30/60 pCi/L, or 0.5; and the fraction contributed by uranium is 150/300 pCi/L, or 0.5.

The sum of these fractions 1s 1.5, which exceeds 1, underground injection of the material would therefore be
prohibited. If, however, the concentrations of radium-226, radium-228, and uranium were 15 pCi/L, 15 pCi/1, and
150 pCi/L, respectively, the fractions would be 15/60 pCi/L, or 00.25 for radium-226, 15/60 pCi/L, or 0.25 for
radtum-228, and 150/300 pCi/L, or 0.5 for uranium. The sum of these fractions (0.25 + 0.25 + 0.5) is 1.
Underground injection of this material would therefore be allowed.

The UIC Program does not regulate single-family residential waste disposal systems such as single-family septic
systems. However, SDWA (Section 1431) gives U.S. EPA the authority to take action on a residential waste disposal
system if the system introduces contaminants into an underground source of drinking water whose presence or likely
presence causes an imminent and substantial endangerment to public health (Section 1431 SDWA).

Table 6 describes the five classes of wells regulated by the UIC Program, the wastes these wells can accept, and the
issues systems should consider before pursuing underground injection as a disposal option. Contact the appropriate

“Under this exclusion, these wastes are not considered to be RCRA “solid waste” and therefore cannot be classified as a hazardous
waste.

19


Acknowledgments

The Guide was prepared for the U.S. Environmental Protection Agency, Office of Water, Office of Ground Water
and Drinking Water, Drinking Water Protection Division by the Cadmus Group, Inc. under contract No. 68-C-02-
069. Special acknowledgment goes to those who helped develop and review the document including: Loren Setlow
and Daniel Schultheisz (U.S. EPA’s Office of Radiation and Indoor Air); Suzanne Kelly (U.S. EPA’s Office of
Ground Water and Drinking Water, Underground Injection Control Program); Robert Bastian and Jan Pickrel (U.S.
EPA’s Office of Wastewater); Stuart Walker (U.S. EPA’s Office of Solid Waste and Emergency Response, Office of
Site Remediation and Technology Innovation); Fred Ferate (U.S. Department of Transportation, Radioactive Materials
Branch); and Catherine Mattsen, Gary Comfort, Andy Imboden, and Charlotte Abrams (Nuclear Regulatory
Commussion, Office of Nuclear Material Safety and Safeguards, Division of Industrial and Medical Nuclear Safety,
Rulemaking and Guidance Branch). Sincere thanks also go to those who participated in the review process and
provided their insights, opinions, and comments.

tii


U.S. EPA. July 18, 1991. “National Primary Drinking Water Regulations; Radionuclides; Proposed Rule.” Federal
Register. Vol. 56, No. 138.

USS. EPA. 1992. “Evaluation of Demonstration Technologies: Quail Creek Water Supply System.” EPA 812-R-93-
001.

US. EPA. 1994a. Drinking Water Glossary: A Dictionary of Technical and Legal Terms Related to Drinking Water. EPA 810-B-
94-006.

US. EPA. 1994b. “Suggested Guidelines for the Disposal of Naturally Occurring Radionuclides Generated by
Drinking Water Plants, W'aste Disposal Work Group.” Office of Drinking Water.

USS, EPA. 1995, “Management of Water Treatment Plant Residuals.” EPA/625/R-95-008.
US. EPA. 1997. Terms of Environment. Revised Editon. EPA 175-B-97-001.

U.S. EPA. May 2000. Regulations on the Disposal of Arsenic Residuals from Drinking Water Treatment Plants.
EPA/600/R-00/025.

U.S. EPA. August 2000. Multi-Agency Radiation Survey and Site Lnestigation Mannal (MARSSIM). EPA 402-R-97-016. Rev.
1.

U.S. EPA. December 7, 2000. “National Primary Drinking Water Regulations; Radionuclides, Final Rule.” Federal
Register. Vol. 65, No. 236.

U

EPA. June 2002. Treatment of Arsenic Residuals from Drinking Water Removal Processes. EP A/600/R-O1 /03.
U.S. EPA. July 2002. EPA Facts About Radium,

USS. EPA. January 2003. RCRA Orientation Manual. Office of Solid Waste and Emergency Response. EPA 530-R-02-
016.

U.S. EPA. November 2003. Advance Notice of Proposed Rulemaking. “Approaches to an Integrated Framework for
Management and Disposal of Low-Activity Radioactive Waste: Request for Comment; Proposed Rule.” Federal
Register. Vol. 82, No. 222.

US. EPA. May 2004, “A Citizen’s Guide to Radon.” Office of Air and Radiation. EPA 402-K02-006.

Wade Miller Associates. July 1991. “Regulatory Impact Analysis of Proposed National Drinking Water Regulations
for Radionuclides." Prepared under contract 68-C0-0069 for the U.S. EPA.

B-3


Section II: Treatment Technologies Overview
II-A Treatment Methods, Residuals, and Disposal Considerations

Tables 8 through 16 provide brief overviews of the uses, efficiencies, disposal considerations, and limitations of the
BATs and SSCTs listed for radionuclide removal, all of which should be considered when choosing an appropriate
treatment technology. In addition, the cost of installing, operating, and disposing of the residuals produced by these
technologies, will be significant factors for systems choosing a new technology. As systems begin initial monitoring
and treatment for, and disposal of these radionuclides, more information on costs will become available.

Note that many of the considerations for solid and liquid residual disposal are identical, regardless of the chosen
treatment technology. These disposal options and considerations, introduced in the previous section, are summarized
below in Table 7. Several of the technologies in Tables 8 through 16 do not have special considerations or limitations.
Note that for systems licensed by the NRC or Agreement State, disposal of residuals may be further restricted.

Table 7: Common Disposal Considerations for Residuals Produced by BAT's and SSCTs

Direct > System must have a NPDES permit
discharge |» — Flow equalization may be required to avoid contaminant spikes
> Appropriate receiving bodies must be available
> — Systems must meet state radionuclides limits

Discharge toa | > — Pretreatment may be required (e.g., flow equalization, pH adjustment, thickening, or chemical precipitation)
POTIF” ptior to discharge to avoid interference with the POTW :
» — Systems must meet the TBLLs established by the state and/or the POTW, abide by the terms of the
arrangement with the POTW, and meet state permitting requirements

rems must determine whether their waste 1s radioactive or hazardous

Underground | > Sy
inection |» — Class 1 hazardous injection wells may be a disposal opton for radioactive or hazardous wastes under

stringent protective measures, and depending on associated constituents and the volume of waste generated

> Class V wells may be a disposal option for non-hazardous, non-radioactive fluids if the system can
demonstrate compliance with CFR 40 part 144.12 (Le., would not cause a violation of any primary drinking
water regulation, adversely affect public health, or otherwise endanger a USDW)

> Single-family septic systems are exempt from federal UIC regulations

ystems should check with their state to determine whether the state has more stringent UIC requirements

+ US. EPA has the authority to take action on any residental waste disposal system if the system introduces
contaminants into a USDW whose presence or likely presence causes an imminent and substantial
endangerment to public health (SDW'A Section 1431).

Landfill |» Systems must determine whether the waste 1s hazardous or non-hazardous (cg., using the TCLP) and

disposal perform the PFLT to determine whether the waste contains free liquids

> Systems must check with their states to determine whether landfilling is an acceptable means of disposal for
hazardous and non-hazardous solid waste containing radionuclides

» The system must choose the appropriate type of landfill, based on the type, volume, and concentration of
solid waste generated

> — The waste must meet all other requirements for landfilling set forth under RCRA, and by the state and the
disposal facility

> — Resins require dewatering prior to disposal; the residual stream generated from dewatering may be disposed
of through direct discharge, discharge to a POTW, or underground injection

> Regenerating the media prior to disposal may reduce its radionuclide concentration (regenerant streams will
need to be disposed of through direct discharge, discharge to a POTW, or underground injection)



Appendix A: Glossary

Agreement State - A state under a signed agreement with the NRC (in which the NRC relinquishes authority to the
Agreement state), that regulates source material, byproduct material, and small quantities of special nuclear material
within the state’s boundaries.

ALARA (As Low As Reasonably Achievable) - Target radiation exposure level, endorsed by the radiation
protection community.” This requires making every reasonable effort to maintain exposures to radiation as far below
the dose limits in [10 CFR 20.1003] as is practical consistent with the purpose for which the licensed activity is
undertaken, taking into account the state of technology, the economics of improvements in relation to state of
technology, the economics of improvements in relation to benefits to public health and safety, and other societal and
socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public
interest. (10 CFR 20.1003)

Alpha radiation - Positively charged, heavy (equivalent to a helium nucleus, two protons, and two neutrons) particles
that are emitted from naturally-occurring and man-made radioactive material (¢.g., from nuclear power or radiation
used in medicine). Examples of alpha emitting radionuclides include radon, thorium, radium, and uranium.

Beta radiation - Beta particles are negatively charged subatomic patticles ejected from the nucleus of some
radioactive atoms. They are typically more penetrating but have less energy than alpha particles. They are equivalent
to electrons, though beta particles originate in the nucleus and electrons originate outside the nucleus.

Examples of beta emitting radionuclides include uranium decay products such as lead-214 and bismuth-214 and
thorium decay products such as actinium-228 and lead-212."

Byproduct material - Any radioactive material (except special nuclear material) yielded in or made radioactive by
exposure to the radiation incident to the process of producing or utilizing special nuclear material (42 USC 2014
(e)(1)), and the tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore
ptocessed primarily for its source material content (42 USC 2014 (@)(2)).

Community Water System - A public water system that serves at least 15 service connections used by year-round
residents or regularly serves at least 25 year-round residents.

Conditionally Exempt Small Quantity Generators - Facilities that produce less than 100 kg of hazardous waste, or
less than 1 kg of acutely hazardous waste, per calendar month, which accumulate less than 1,000 kg of hazardous
waste, 1 kg of acutely hazardous waste, or 100 kg of spill residue from acutely hazardous waste at any one time.”

Curie/picocurie - A measure of radioactivity. One Cutie of radioactivity is equivalent to 3.7 x 10" or 37,000,000,000
nuclear disintegrations pet second.** Concentrations of radioactivity in solid materials in the environment are usually
expressed as picocuries per gram (pCi/g) while radioactivity in air or liquids is expressed as picocuries per liter
(pCi/L). One picocure is one trillionth of a curie.

S. DOE, 1997,

Maatpa! Sew opr gut ridiauon anderstar

2y,

A, 197.

EPA, January 2003,

2PA, 1994a,
Ad


I-E Worker Exposure and Safety

Because radiation is invisible, tasteless, and odorless, it is commonly overlooked as a potential hazard at water systems.
Exposure to elevated levels of radiation at water treatment facilities may cause serious health effects. Systems need to
determine whether a radiation problem exists and, if it does, take appropriate safety precautions to prevent or limit
water system staff members’ exposure to radiation. For example, if a system tested its treated water 2 years ago and
found levels of 3pCi/L for radium-226 and 228, a radiation survey of the facility would be prudent.

Water system staff can be exposed to radiation during normal treatment processes for radionuclides, through handling
the residual streams generated by treatment, and during media replacement or transportation. Relatively undetectable
levels of radionuclides in source waters can accumulate in measurable ot hazardous quantities in piping, pumps,
holding tank scale or sludge, IX and granular filters, backwash, and other residual sludge. Radon gas can accumulate
in closed or poorly ventilated buildings when thorium, uranium, ot radium-bearing materials (including water) are
present. Naturally occurring radon gas can enter through openings in the building’s concrete or foundation walls.
Underground connections to manholes, piping conduits, and utility tunnels provide additional pathways for radon
entry. For example, elevated gamma tay levels have been found around IX columns and associated piping at some
facilities. This could result in an exceedance of public dose limits

I-E.1 Radiation Surveys

A system should contact a professional radiation protection specialist or a health physicist for assistance in conducting
a radiation survey if: (1) the system has had an analytical result within the past 5 years that has approached or has
exceeded an MCL. for a regulated radionuclide; or, (2) if calculations derived from use of the U.S. EPA SPARRC
model indicates potential concentrations of radioactivity in residuals and filters at the system."”

A radiation survey can be conducted by:

1. 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.

3. Sampling filter media, wastes, and water through further laboratory analyses. These analyses should focus on
finding the principal NORM/TENORM isotopes found in surface and groundwater supplies: radium,
uranium, thorium, and potassium as well as their radioactive daughter decay products.'*

Some states require radiation protection specialists or health physicists who conduct radiation surveys (including radon
sutveys) to be certified or licensed. State Radiation Control contact information appears in Appendix D.

A\s a result of the survey, the system may need to establish a monitoring program, change existing management
practices, alter methods for managing radioactively contaminated equipment and wastes, or establish worker radiation
safety and education programs. The survey may also recommend methods for decontaminating buildings or facilities,
if needed.

"A working draft of SPARRC 1s available for estmaung the volume and concentration of radionuclides in waste produced by water
systems. The program allows the operator to select the type of treatment process, as well as input and output parameters such as
water flows, doses of coagulant and polymer, and filter capacities. To view the spreadsheet, see

"Decay products such as isotopes of radon, lead, polonium, and bismuth may need to be analyzed in order to calculate the
concentrations of the original parent radionuclide such as radium or uranium, Characterizing the types and amounts of radionuchdes
present will be beneficial in denufving sources in the drinking water, understanding how, where, and why they are collecung in the
treatment plant, correcung a contaminauon problem in the plant through selection of treatment technologies and management
techniques, and aiding management in deciding where hazardous waste products should be disposed or where they might be accepted.

22



Table 3: Ap

licability of Best Available Technologies and Small System Compliance Technologies®

Treatment Designation | Customers Treatment Capabilities Source Water Operator
Technology Served Considerations Skill
BAT and/or er Radium | Uranium | Gross \ Beta/p Required
SSCT? only) (Ra) &) | Apha | boton
(G) (B)
IX BAT & SSCT }  25-10,000 ov ov o All ground Intermediate
waters
Point of Use SSCT 25-10,000 a ov oc All ground Basic
(POL) IX waters
Reverse BAT & SSCT | 25-10,000 oc oc o 7 | Surface waters Advanced
Osmosis (RO) (Ra, G, B) usually requiring
501-10,000 pre-tiltration
we)
POU RO SSCT 25-10,000 vo co cv a Surface waters Basic
usually requiring
pre-filtration
Lame Softening | BAT & SSCT | 25-10,000 oc a All waters Advanced
(Ra)
501-10,000
wu)
Green Sand SSCT 25-10,000 oS Typically Basic
Filtration ground waters
Co-precipitation SSCT 25-10,000 oc Ground waters | Intermediate
with Barram with suitable | to Advanced
Sulfate water quality
Llectrodialysis/ SSCT 25-10,000 v All ground Basic to
Electrodialysis waters Intermediate
Reversal
Pre-formed SSCT 25-10,000 vo All ground Intermediate
Hydrous waters
Manganese
Oxide Filtration
AA sscT 25-10,000 oc All ground Advanced
waters
Coagulation/ | BAT & SSCT } 25-10,000 ov Wide range of | Advanced

Filtration

water qualities

°U.S. EPA, December 2000.

6



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Office of Water (4606M)
EPA 816-R-05-004

July 2005
www.epa.gov/safewater

Printed on Recycled Paper


Appendix C: Applicable Federal Statutes and Regulations

Atomic Energy Act (AEA)

The 1954 AEA regulates the development and use of nuclear facilities, and the creation, generation, and disposal of
source, special nuclear, and byproduct material (all designated as radioactive material under the jurisdiction of the
AEA). The Act enables the NRC to establish relationships with states that allow these “Agreement States” to develop
and implement regulations governing the use and possession of source, special nuclear, and byproduct materials.
Agreement States must establish radiation protection programs compatible with the NRC’s; for a list of Agreement

States, see hup:/ www.hsrd.orn gov /ore,

NRC has exempted source material from regulation under the AEA if the uranium or thorium makes up less than 0.05
percent by weight (.c., an “unimportant quantity”). Equivalent exemptions appear in the Agreement States’
regulations. For natural uranium, this is equivalent to approximately 335 pCi/g, and therefore, the uranium residuals
ptoduced by water treatment plants may, in some cases, be an “unimportant quantity of source material” and exempt
from NRC’s and the Agreement States’ regulations. Source material may be held under a general license if it is greater
than 0.05 percent by weight, but the total amount in a treatment plant’s possession at any time is less than 15 pounds.
This is referred to as a “small quantity” of source material. The general license to use and transfer small quantities of
source material is granted under 10 CFR 40.22 and equivalent regulations of the Agreement States. Under this general
license, systems may not process more than 150 pounds of source material in a calendar year. Systems that exceed the
small quantity thresholds must apply for a specific license from the NRC or Agreement State.

The NRC’s “Standards for Protection Against Radiation” (10 CFR Part 20), contains the basic radiation protection
standards for persons licensed to receive, possess, use, transfer, and dispose of source, special nuclear, and byproduct
materials as defined in the AEA. These regulations set dose limits for radiation workers and the public, and specify
tequirements for the monitoring and labeling of radioactive materials, the posting of radiation areas, and the reporting
of theft or loss of radioactive material. Regulations for licensing of source material are contained in 10 CFR Part 40.
Additional requirements for persons licensed by the NRC are contained in 10 CFR Part 19; this includes requirements
for instructions and notifications to employees. The NRC’s Regulations can be found at

http:

Aww ire voy / reading-rm/doc-collections/ cfr

Because the NRC’s transportation duties overlap with the statutory authority of the DOT, the NRC and DOT signed
a Memorandum of Understanding in 1979 covering the regulation of the transport of radioactive materials.

For more information, see
hirp:
ks&page=14 and herp

wow ore.gov/ reading rm /doc-collecuons /nuresy/ sath or0080 / m10222000754 ol pdt pagemode=bookmar

warw ore.gov, who-weare hil.

Clean Water Act (CWA)

Wastes generated by water treatment plants and discharged to a receiving body of water (direct discharge) or to a
POTW are regulated under the CWA. The Act requires dischargers to have a NPDES permit in order to discharge
any pollutants into waters of the United States.

When applying for a NPDES permit, systems must provide information on water temperature, pH, flow rate, and on
pollutant levels in the discharge. For copies of NPDES application forms, see
bitpy /cfpub.cpa. cow /npdes/doctype.cfm?sor=name&program id=45

5&document pe id=s.

See hry
program.

fpub.cpa.gos /npdes, m for a list of states that are authorized to administer the NPDES

Statestats

The CWA can also require systems to pretreat waste prior to discharge to a POTW. POTWs are required to establish
and enforce pretreatment programs identifying significant dischargers who are subject to pretreatment standards (40
CER 403). If a system wants to discharge its waste to a POTW, both the system and the POTW are responsible for

CA


regulated by the NRC, or Agreement States (see “Nuclear Regulatory Commission (NRC) Regulations” on the
previous page, and 10 CFR 61 and 62 for more detail).

Resource Conservation and Recovery Act (RCRA)

The disposal of solid wastes® (including sludge) 1s regulated under RCRA (unless it is disposed of via direct discharge
or underground injection). Under RCRA, an entity or person generating a solid waste must determine whether the
waste is hazardous using the method described in 40 CFR 262.11.

Solid waste exhibiting toxicity, corrosivity, reactivity, or ignitability characteristics is hazardous. Hazardous waste
requires special handling and disposal, and it is subject to RCRA Subtitle C requirements.

If the system wishes to dispose non-hazardous waste in a landfill, RCRA Subtitle D requirements apply. It is
recommended that water treatment plants operate in a way that will avoid any generation of hazardous waste.

Municipal Solid Waste Landfill (MSWLE) Requirements

U.S. EPA, through the MSWLF Requirements (40 CFR 258, under RCRA Subtitle D), ensures the protection of
human health and the environment by setting minimum national criterta for MSWLFs. A municipal solid waste
landfill is a discrete area of land or excavation that receives household waste. A MSWLF may also receive other types
of RCRA Subtitle D wastes, such as commerctal solid waste, nonhazardous sludge, Conditionally Exempt Small
Quantity Generator (CESQG) waste, and industrial nonhazardous solid waste.

These federal requirements cover landfill location, operation, and design; ground water monitoring; corrective action;
closure and post-closure, and financial assurance. States and MSWLFs may have additional requirements. For more
information on municipal solid waste management, see http: i

Safe Drinking Water Act (SDWA) - Underground Injection Control (UIC) Program

US. EPA is directed by the SDWA to establish minimum federal requirements for state and UIC programs to protect
underground sources of drinking water (USDW’s) from contamination caused by underground injection activities.
Protection includes the oversight of construction, operation, and closure of injection wells. A treatment residual
generator interested in UIC as a disposal option should contact the appropriate U.S. EPA regional or state UIC
program office to determine the statutory requirements in their state.

Any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, of air pollution control facibty, and
other discarded matenal, including solid, liquid, semisod, or contained gaseous material, resulting from industrial, commercial,
mining, and agricultural operations and from community acuvities. For the purposes of hazardous waste regulation, a solid waste 18 a
material that is discarded by being either abandoned, inherently waste-ke, a certain waste military munition, or recycled.



D Disposal of Residuals: An Overview of Applicable Statutes, Regulations,
and Disposal Options

Treating water for naturally occurring radionuclides will result in residual streams that are classified as “technologically
enhanced naturally occurting radioactive materials,” or TENORM.* TENORM is defined here as naturally occurring
materials, such as rocks, minerals, soils, and water whose radionuclide concentrations or potential for exposure to
humans or the environment ts enhanced as a result of human activities (e.g., water treatment).’ Pilot tests of treatment
technologies are a good way for systems to determine how much waste will be produced, and whether the system will
be capable of disposing of the amount, concentration, and type of waste.

Numerous regulations govern the disposal of waste streams containing radionuclides (although there are no federal
waste disposal regulations specifically for TENORM wastes), and their interaction is complex. States and disposal
facilities can place additional restrictions on systems’ disposal options.

I-D.i Applicable Federal Statutes and Federal Regulations
The following federal statutes and regulations could potentially apply to the disposal of water treatment residuals:

» The Resource Conservation and Recovery Act (RCRA; 40 CFR 239 to 282) establishes programs for
regulating nonhazardous solid waste (Subtitle D), hazardous waste (Subtitle C), and Underground Storage
Tanks (Subtitle 1). RCRA governs the identification, classification, and management of solid'” and hazardous
wastes.'' The RCRA regulations that apply to different types of disposal units depends on the types of wastes
that are accepted.

* Municipal solid waste landfills (MSWLF) are Subtitle D landfills that accept household and other
municipal waste. A MSWLF may receive other types of RCRA Subtitle D wastes, such as commercial
and industrial wastes. The Municipal Solid Waste Landfill (MSWLF) requirements (40 CFR 258), establish
minimum national criteria for MSWTFs covering landfill location, operation, and design; ground water
monitoring; corrective action; closure and post-closure, and financial assurance.

* Subtitle D landfills that accept nonhazardous waste, but do not accept municipal waste (“industrial
landfills”), are also subject to federal regulations (40 CFR Part 257, Subparts A and B). However, state
regulations typically have additional requirements that apply to these industrial landfills.

* — Land disposal units that accept hazardous waste are regulated under Subtitle C, and include landfills,
surface impoundments, waste piles, land treatment units, and underground injection wells. These
disposal units are subject to stringent design and operating standards (40 Parts 264 and 265).

bippe! war epayor radius Vtenorm for more information.

"Thus definition 1s in accordance with the concepts presented in National Academy of Sciences. 1999, Evaluation of Gurdelnes for
Exposures to Technologically Enhanced Naturally Qunrrmg Radioactive Materials. Washington, D.C.: National Academies Press; and LALA
(2004),

“Any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or att polluuon control facility, and
other discarded material, including solid, quid, semisolid, or contained gaseous material, resulting from industrial, commercial,
mining, and agricultural operauons and from community activites. (U.S. EPA, Mied Waste Glossan) For the purposes of hazardous
waste regulation, a solid waste is a material that is discarded by beng either abandoned, inherently waste-ike, a certain waste military
munition, or recycled. (U.S. EPA, 20003)

“Hazardous waste is defined under 40 CFR 261.3. Waste 1s considered hazardous if it is a solid waste (as defined under 40 CFR
261.2) that 1s not excluded from regulation as hazardous waste under At) 261.4(b) and when it meets the criteria listed under 40 CPR
261.3(a)(2) and (b).

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