SEPA
United States
Environmental Protection
Agency
A System's Guide to the
Management of Radioactive
Residuals from Drinking Water
Treatment Technologies
Cmmunity water systems (CWSs) that use source water containing radium-226 (Ra-226), radium-228 (Ra-228),
gross alpha particle activity, beta particle and photon radioactivity, or uranium must comply with the Radionuclides Rule
(see www.epa.gov/safewater/radionuc.html). This document provides general information to CWSs on: the available
treatment technologies for the removal of radium, uranium, and gross alpha particle activity; the residuals produced by each
technology; disposal options; and, the regulations governing these options. These requirements are decribed here in summary
form only and there may be additional federal or state laws or regulations that apply to you beyond those described in this
document. You need to consult the statutory and regulatory provisions that apply to the waste you generate or manage in
order to determine the requirements with which you must comply. This document also provides additional recommendations
and information on possible options; these are not regulatory requirements and are provided for your information only. This
document does not cover residuals from treatment of beta particle or photon radioactivity. Information on those
radionuclides can be obtained from your primacy agency. EPA will continue to review and update this Guide as necessary
and appropriate. For additional, more detailed information see A Regulators' Guide to the Management of Radioactive Residuals from
Drinking Water "treatment "technologies (EPA 816-R-05-004, July 2005).
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Treatment Technologies
In the Radionuclides Rule, EPA has listed Best Available
Technologies (BATs) and Small System Compliance
Technologies (SSCTs) for radionuclide treatment based on
their efficiency at removing radionuclides from drinking
water, taking cost into consideration. You are not required
to use a listed BAT or a SSCT. Any technology that is
accepted by your primacy agency and achieves compliance
with the maximum contaminant level (MCL) is allowed.
These technologies produce different types of waste with
varying contaminant concentrations and restrictions on
disposal options. It is important that systems carefully
investigate treatment and waste disposal options before
installing new or upgrading existing treatment. If possible,
pilot tests are a good way to determine how much waste
your system will produce and whether your system will be
able to dispose of the amount, concentration, and type of
waste.
Treatment and Disposal
Considerations
Treatment Residual Characteristics
Each treatment technology will produce solid residuals
(spent resins, spent filter media, spent membranes, and
sludge) and liquid residuals (brine, backwash water, rinse
water, acid neutralization streams, and concentrates). The
characteristics of the residuals can be affected by:
• The concentration of radionuclides in the source
water
• Frequency of resin/media/membrane replacement
• How efficient the treatment is at removing
radionuclides
• Loading to the treatment unit
• Frequency of regeneration (for ion exchange and
activated alumina)
• Frequency of filter backwash (for treatment
processes using granular media filters)
TENORM
Treating water containing naturally occurring radionuclides
increases the radionuclide concentrations in the residual
streams. These residual streams are called Technologically
Enhanced Naturally Occurring Radioactive Materials
(TENORM), or naturally occurring materials whose
radionuclide concentrations or potential for exposure to
humans or the environment are enhanced as a result of
human activities. The concentration of TENORM in the
waste stream, the type of waste produced (liquid or solid),
and federal and state regulations will affect what disposal
options are available to your system.1
Nuclear Regulatory Commission Licensing
If your system generates water treatment residuals
containing uranium or thorium, this uranium or thorium is
considered "source material" and may be subject to the
Nuclear Regulatory Commission's (NRC's) licensing
requirements under the Atomic Energy Act (AEA).
Licenses are issued either directly by the NRC or by
"Agreement States" that have entered into agreements with
the NRC to regulate source material. If you think your
system may require a license, contact your primacy agency.
Exempt Material: If the uranium or thorium makes up less
than 0.05 percent by weight of the residuals it is exempt
from NRC regulations because it is considered an
"unimportant quantity" (10 CFR 40.13). For perspective,
for a system with filter media weighing 30,000 pounds, 0.05
percent by weight would be equal to 15 pounds of uranium.
General License: If the source material is greater than 0.05
percent by weight (or about 335 picocuries per gram [pCi/
g] for natural uranium), and the total amount in your
possession at any time is less than 15 pounds or no more
than 150 pounds in any one calendar year, you have a
"small quantity" of source material that is subject to a
general license (10 CFR 40.22).
Specific License: If your system exceeds this small quantity
threshold, you must apply for a specific license from the
NRC or Agreement State.
Resource Conservation and Recovery Act Requirements
Also, since many of the treatment technologies that are
efficient at removing radionuclides are also efficient at
removing co-occurring contaminants, your TENORM
residuals may also be classified as hazardous waste if they
contain high enough levels of certain co-occurring
contaminants, like arsenic. Under the Resource
Conservation and Recovery Act (RCRA), a waste is
considered hazardous if it exhibits a certain characteristic
(i.e., toxicity, ignitability, corrosivity, or reactivity) or if it is
included on a specific list of wastes. Water treatment plant
residuals are most likely to exhibit the toxicity characteristic.
For more information, see A System's Guide to the Identification
and Disposal of Hazardous and NTon-Hazardous Water Treatment
Plant Residuals (EPA 816-F-06-011).
1 The pH and total dissolved solids (TDS), total suspended solids (TSS), and concentrations of other contaminants in the waste stream can also limit
disposal options.
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Mixed Waste
If your treatment residuals contain hazardous waste and a
"small quantity" of uranium or thorium, you have a mixed
waste and you must comply with both RCRA hazardous
waste regulations and NRC's licensing requirements. These
requirements also apply to the recipient of the material (i.e.,
a hazardous waste landfill). You do not have a mixed waste
if the uranium or thorium is of an "unimportant quantity"
(uranium or thorium makes up less than 0.05 percent by
weight of the material), or if the waste contains only radium.
Radium is not considered source or by-product material
when present in water treatment residuals unless it co-
occurs with licensable source material such as uranium or
thorium.
Table 1 lists the BATs and SSCTs listed in the
Radionuclides Rule and includes information on the
operator skill required to effectively operate each
technology, the residuals produced, and intermediate
processing options. Intermediate processing can increase
the disposal options available to your system and in some
cases, can reduce the volume of waste produced. Systems
can also consider several alternative compliance options
including: developing a new source, blending source waters,
connecting with a nearby system, or optimizing existing
treatment.
Disposal Options
Your disposal options will vary according to: primacy
agency regulations; your system's location; and the type,
volume, and concentration of residuals your system
produces. There are numerous state and local regulations
that 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. Primacy agencies and disposal
facilities can impose additional restrictions on your system's
disposal options. Check with your primacy agency to
verify which disposal options are available to your
system.
Table 2 provides additional general information on disposal
options for water treatment plant wastes containing
radionuclides.
Table 1: BATs and SSCTS for the Removal of Radionuclides
Treatment
Ion Exchange (IX)
Point of Use (POU) IX
Reverse Osmosis (RO)
POURO
lime Softening
Green Sand Filtration
Co-precipitation with
Barium Sulfate
Pre-formed Hydrous
Manganese Oxide
Filtration
Coagulation/Filtration
Activated Alumina (AA)
Electrodialysis /
Electrodialysis Reversal
BAT
and/or
SSCT?
BAT&
SSCT
SSCT
BAT&
SSCT
SSCT
BAT&
SSCT
SSCT
BAT&
SSCT
SSCT
Customers
Served
(SSCTs only)
25 - 10,000
25 - 10,000
25 - 10,000
(Ra, GA)
501 - 10,000 (U)
25 - 10,000
25 - 10,000 (Ra)
501 - 10,000 (U)
25 - 10,000
25 - 10,000
25 - 10,000
Ti
226/
228
•
•
•
•
•
•
•
•
•
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from Drinking Water
:ats For...
U
*
*
•
•
•
•
Gross
Alpha
(GA)
*
•
Source
Water
Ground
Surface
All
Ground
All
Ground
Operator
Skill
Required
Intermediate
Advanced
Basic
Advanced
Basic
Intermediate
to Advanced
Intermediate
Advanced
Advanced
Basic to
Intermediate
Solid
Residuals
Spent resins
Spent
membranes
Spent filter
media,
sludge
Spent filter
media
Spent
membranes
Intermediate
Process Options
Regeneration prior
to disposal
Dewatering,
regeneration prior
to disposal
Spent filter media:
Regeneration prior
to disposal
Sludge: Thickening,
dewatering, recycle
Filter media:
Dewatering,
regeneration prior
to disposal
Sludge: Thickening,
dewatering, recycle
Dewatering,
regeneration prior
to disposal
Regeneration prior
to disposal
Liquid
Residuals
Backwash
water, brine,
and rinse water
Concentrated
waste stream
Spent filter
backwash
water
Spent filter
backwash
water, filter-to-
waste (if
practiced)
Backwash
water, brine,
rinse water,
acid
neutralization
water
Concentrated
waste stream
Intermediate Process
Options
Flow equalization,
chemical
precipitation/pH
adjustment, thickening,
dewatering, recycle
Chemical
precipitation/pH
adjustment, thickening,
dewatering, recycle
Flow equalization,
chemical
precipitation/pH
adjustment, thickening,
dewatering, recycle
Chemical
precipitation/pH
adjustment, thickening,
dewatering, recycle
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Table 2: Options for Residual Disposal
Below is general information on the basic disposal requirements. Always contact your primacy agency before choosing
a disposal option, as additional requirements may apply depending on primacy agency regulations, disposal facility
restrictions, and the type and characteristics of the waste. A 'Regulators' Guide to the Management ofRadioactive Residuals
from Drinking Water Treatment Technologies (EPA 816-R-05-004, July 2005) includes two decision trees (see pages 17 and
21) that can also help you.
Options for Solid Residuals1
For landfill disposal, solid wastes must not contain free liquids2 and may need to be dewatered prior to disposal.
Disposal Option 1: Municipal &
Industrial Solid Waste Landfill
1. Regulated under RCRA, Subtitle D
2. Ability to dispose of hazardous
waste depends on generator class;
contact your primacy agency for more
information
3. Industrial solid waste landfills may
be belter equipped to dispose of
TENORM wastes than municipal
landfills, which may have restrictions
on the amount of radioactivity they
can accept
4. Some landfills may use monitors to
scan incoming trucks for radiation
Disposal Option 2: Hazardous
Waste Landfill
1. Regulated under RCRA, Subtitle C
2. Not all hazardous waste landfills
accept TENORM waste
3. Certain generator classes must
meet Land Disposal Restrictions in
40 CFR Part 268; contact your
primacy agency for more information '
Disposal Option 3: Low-Level Radioactive
Waste (LLRW) Landfill
1. Regulated by the NRC or Agreement State
2. May accept wastes with radionuclide
concentrations too high for disposal at a solid or
hazardous waste landfill
3. Guidelines for disposal are more stringent than
in a standard landfill
4. Currently, only three LLRW landfills are
operating, with differing restrictions on waste
disposal (e.g., which states can dispose of waste,
types of wastes accepted, etc.); contact your
primacy agency for more information
Options for Liquid Residuals
Disposal Option 1: Direct
Discharge to Waters of the U.S.4
1. Regulated under the Clean Water
Act (CWA)
2. Must have a National Pollutant
Discharge Elimination System
(NPDES) permit
3. Need an appropriate and accessible
receiving body
4. Must meet primacy agency water
quality limits for radionuclides
Disposal Option 2: Discharge to a
Publicly Owned Treatment Works
(POTW)
1. Regulated under the CWA
2. Must meet Pretreattnent Program
prohibitions and the Technically
Based Local Limits (TBLLs)
established by your state or the
POTW (i.e., discharge cannot cause a
NPDES violation)
3. Must meet any POTW
requirements
4. Must meet state permitting
requirements
5. Additional conditions apply to
systems that combine liquid wastes
with domestic sewage prior to
discharge; contact your primacy
agency for more information
Disposal Option 3: Underground Injection
1. Regulated under the Safe Drinking Water Act
(SDWA)
2. In accordance with UIC regulations (10 CFR
20 Appendix B, Table 2, Column 2), EPA
considers wastes with the following concentrations
of radium and uranium to be radioactive: 60
pCi/L for radium-226, 60 pCi/L for radium-228,
and 300 pCi/L for uranium
Class I Well Considerations
1. May be an option for hazardous and
radioactive wastes, but very few Class I facilities
accept hazardous or mixed waste generated off-
site
2. Wells have stringent protective requirements
3. Can be expensive to construct, operate, and
monitor
4. Acceptable geology not always available
5. States may be more stringent or may prohibit
such class of injection well
Class V Well Considerations
1. Not an option for wastes considered hazardous
2. Most likely not an option for radioactive
waste, because demonstration of the non-
endangerment standard (40 CFR 144.12) for
shallow injection will be difficult
1 Discharge to a POTW and underground injection are also possible options for sludge disposal.
2 See 40 CFR 264.314(b) and (e) and 40 CFR 265.314(b) and (f).
3 For more information on the disposal of hazardous waste, see EPA's A System's Guide to the Identification and Disposal of Hazardous and Non-
Hazardous Water Treatment Plant Residuals (EPA 816-F-06-011).
4 Direct discharges subject to NPDES permits are not solid or hazardous waste under RCRA. However, wastewater that is stored before
discharge is considered solid waste, may be hazardous, and is thus regulated by RCRA.
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Transporting Waste
The U.S. Department of Transportation (DOT) regulates the safe transport of all hazardous materials,
including radioactive material. DOT has set radionuclide-specific thresholds to determine when a material
containing radionuclides is subject to requirements for transporting radioactive material. The exemption
values (listed in 49 CFR173.436) consist of activity concentrations and total consignment activities; a material
containing a single radionuclide has to be above both exemption values for that nuclide to be subject to
DOT requirements. If the activity concentration or total consignment activity is below the exemption value,
that material is exempt from the DOT requirements for transporting radioactive material. If more than one
radionuclide is present, the exemption values must be determined as described in 49 CFR 173.433.
DOT also exempts "natural material and ores containing naturally occurring radionuclides which are not
intended to be processed for use of these radionuclides" if their activity concentrations and consignment
activities do not exceed 10 times the levels in 49 CFR 173.436 or calculated using 49 CFR 173.433. For
example, the exempt activity concentration for uranium is listed as 27 pCi/g, and those for radium-226 and
radium-228 are 270 pCi/g. Therefore, if your system transports more than 270 pCi/g of uranium or 2,700
pCi/g of radium, you must comply with DOT's requirements for radioactive material transport (unless
consignment activities are below the consignment activity exemption). For more information, see http://
hazmat. dot.gov.
Additional Resources
Documents and Web Sites
EPA Office of Ground Water and Drinking Water:
• Radionuclides in Drinking Water: www.epa.gov/safewater/radionuc.html
• Radionuclides Rule (Final), Federal Register, Vol. 65, No. 236, December 7,2000
• Radionuclides Rule Implementation and Guidance: www.epa.gov/safewater/rads/implement.html
• Implementation Guidance for Radionuclides, EPA 816-F-00-002, March 2002
• Radionuclides in Drinking Water: A Small Entity Compliance Guide, EPA 815-R-02-001, February 2002
• Radionuclides Rule: A Quick Reference Guide, EPA 816-F-01-003, June 2001
• A Regulators' Guide to the Management of Radioactive Residuals from Drinking Water ^Treatment ^Technologies
EPA 816-R-05-004, July 2005
• Underground Injection Control: www.epa.gov/safewater/uic.html
EPA Office of Air and Radiation:
• Radiation Protection Division: www.epa.gov/radiation/index.html
• TENORM: www.epa.gov/radiation/tenorm/index.html
EPA Office of Solid Waste: www.epa.gov/osw
EPA Office of Wastewater Management, NPDES: cfpub.epa.gov/npdes
RCRA Online: www.epa.gov/rcraonline
The TENORMPage: www.tenorm.com
U.S. Nuclear Regulatory Commission: www.nrc.gov
Safe Drinking Water Hotline 1-800-426-4791
Office of Water (4606M)
EPA 816-F-06-012
www.epa.gov
August 2006
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