United States
    Environmental Protection
    Agency
Using DWSRF  Funds to Comply with
the Radionuclides Rule
The Drinking Water State Revolving Fund (DWSRF) program was established by the 1996 Safe Drinking Water Act (SDWA)
Amendments and authorizes grants to states to capitalize revolving loan funds.  The states provide low-interest loans to eligible
systems for infrastructure improvements needed to ensure compliance with the SDWA and protect public health.  The
DWSRF program can play a significant role in helping systems, especially small systems, to meet the challenges of complying
with new drinking water standards.

The Environmental Protection Agency (EPA) published revisions to the Radionuclides Rule on December 7, 2000 which
further protect the public from exposure to radioactive substances in drinking water. The revisions include a new uranium
maximum contaminant level (MCL) of 30 ppb and a requirement to monitor separately for radium-226 and radium-228,
resulting in an increased number of systems out of compliance with the combined radium MCL. These changes will impose a
financial burden on some water systems. The DWSRF can provide assistance to systems to help ease this burden, increase
compliance, and protect public health.


WHY  DID EPA CREATE THIS RULE?
EPA began regulating radionuclides in 1976 by establishing MCLs under the SDWA. In the quarter century since, EPA has
learned more about the potential health effects from consuming water with high concentrations of radionuclides. The new
uranium MCL of 30 ppb will provide additional protection for 620,000 people and decrease the incidence of cancers and
kidney problems. Due to the mistaken conclusion that systems with low levels of radium-226 would also have low levels of
radium-228, the current standards only required analysis of radium-228 when levels of radium-226 exceeded 3 pCi/L.  Based
on a better understanding of radium-228 incidence, EPA closed this loophole by requiring separate monitoring for radium-
228. This change will reduce radium exposure for 420,000 people and reduce the incidence of cancer.
TO WHOM DOES THIS RULE APPLY?
The Radionuclides Rule applies to all community
water systems (CWSs). Of all affected systems,
98% are small systems that serve fewer than 10,000
people. Higher levels of radionuclides tend to be
found in ground water rather than surface water
sources (i.e., lakes  and rivers).  Compared to the
rest of the United  States, western states and states
in the Great Lakes region tend to have higher
occurrence of radionuclides in ground water.
                         Surface Water   v
                         Ground Water   v
                          GWUDI     /
  CWSs    /
NTNCWSs
 TNCWSs
   < 10,000    /
10,000-100,000 /
   > 100,000   /
CRITICAL RULE DEADLINES & REQUIREMENTS
FOR SYSTEMS*

December 8, 2003
December 31 , 2007

States began updating vulnerability assessments for beta photon and particle emitters and notifying systems of
monitoring requirements.
EPA explained new rules and requirements to states.
Deadline for states to submit primacy revision application to EPA.
New MCL and monitoring requirements take effect. Systems must begin initial monitoring. When allowed by
the state, systems may be permitted to grandfather data collected before this date and June 2000.
Initial monitoring must be completed.
FOR STATES
December 8, 2000
Spring 2001
December 8, 2002

'Deadlines for a specific system may be affected by variances or exemptions granted by the State.

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HOW WILL THIS RULE IMPACT SYSTEMS?
                                                                 Figure I: TOTAL RADIONUCLIDES
                                                                RULE PRICE TAG (in millions of 1999 $)
                                                                Uranium MCL
                                                                Closing Radium-228 Loophole
                                                                                                     Capital Costs
                                                                                                    by System Size
                                                                                           $215
                                                                                           $131
The costs systems will face to meet the new Radionuclides Rule
are significant.  Systems will incur capital costs for two require-
ments under the rule:
    Compliance with the new uranium MCL of 30 ug/L; and
    Closing the combined radium monitoring loophole by
    requiring separate monitoring for radium-228.
The total capital costs for investments in treatment technology
and infrastructure to meet these provisions are estimated to be
almost $350 million (see Figure 1).  In addition, annual opera-
tion and maintenance (O & M) and monitoring costs for
systems will top $34 million. As shown in Figure 2, most of the affected CWSs are ground water systems (radium is normally
                                         not present in appreciable levels in surface water).
                                                               CAPITAL COST G RAN D TOTAL  $346
                                                               Annual O & M Costs
                                                               Annual Monitoring Costs
                                                                                             $31
                                                                                             $3
                                                                 < 100
                                                                101-500
                                                               501-1,000
                                                              1,001-3,300
                                                             3,301-10,000
                                                            10,001-100,000
                                                               > 100,000
                                  $4
                                  $14
                                  $11
                                  $29
                                  $38
                                 $142
                                 $108
 Figure 2: Percent of Systems Affected
 by the Radionuclides Rule
                         0.2%
                         ^_
         Ground Water  Surface Water
                                        Approximately 53,156 CWSs are subject to the provisions of the Radionuclides
                                        Rule, less than 1,000 of which will have to install treatment.  EPA estimates that
                                        98% of the systems that will need to take action to come into compliance with
                                        the uranium or combined radium MCLs serve less than 10,000 people.  There-
                                        fore, most of the capital costs created by the rule will fall on the shoulders of small
                                        water systems (see Figure 3).  Most of these systems will have to take action to
                                        comply with the new uranium MCL.
                                         Figure 4 illustrates how much it will cost systems (on average) to meet the new
                                         standards.  Systems that would be out of compliance with the new uranium MCL
                                         may have to install new technologies, upgrade existing technologies, consolidate
                                         into larger systems, or develop new water sources.  The requirement to monitor
separately for radium-228 and radium-226 will result in more systems facing non-compliance with the combined radium
MCL, creating infrastructure needs and annual compliance costs similar to those for the uranium  MCL. With the closing of
the radium monitoring loophole, approximately 270 to 320 systems currently in compliance with the combined radium MCL
due to assumed low levels of radium-228 will now have to take action to retain their compliance status.

The average increase in costs per household to meet the new uranium MCL and the new radium monitoring requirements
depends on the size of the water systems and how many people are served by that system. The estimated compliance cost per
system is considerably lower for small systems than for large systems because less water must be treated. However, the burden
on small system households is significantly higher because the costs must be paid from a much smaller revenue base. EPA
estimates that the average annual household water bill for ground water systems out of compliance may increase by $18-$ 180
for the uranium MCL and $8-$ 126 for the combined radium MCL. The uranium compliance costs will be significantly
cheaper for surface water systems ($3-$72 per household).
  Figure 3: Number of CWSs Affected by the
  Radionuclides Rule
                                                            Figure 4: Average Annual Compliance Cost per CWS
                                                            Exceeding Uranium or Combined Radium MCL
                                                            (in thousands of 1999 $)
        25-100
                IOI-
                500
                        50I-
                        1,000
                              1,001-
                              3,300
3,301-  10,001-
10,000  100,000
                                                                    25-100
101-
500
1,001-
3,300
3,301-  10,001-
10,000  100,000
                     Population Served
                        501-
                        1,000
                      Population Served
Note: Costs based on total costs amortized over 20 years at a 3% discount rate.

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WHAT TYPE OF TREATMENT WILL SYSTEMS HAVE TO PUT IN PLACE?
Exhibit 1 : Radionuclide Treatment Technologies & Strategies*
Treatment Technology or
Strategy
1
2
3
4
5
6
Lime Softening**
Ion Exchange/
Activated Alumina
Reverse Osmosis
Enhanced Coagulation/
Filtration***
Greensand Filtration
FOR..
Uranium
  
  
  
9 99 9

Combined
Radium
 
 
 

 
Surface
Water?
YES 
4
4
YES

POU
Option

YES
YES


Other, including source change, regionalization, and blending.
 ^ Best Available Technology
 = Small System Compliance Technology
                                                             'Referenced in Figures 5 and 6.
                                                             "Central treatment is only uranium SSCT for systems >500.
                                                             "'Assumes that a system already has coagulation/filtration in place.
There are many available technologies capable of removing
radionuclides. These treatment options differ greatly in terms
of capital and O & M costs and operator skill required for
proper operation. The characteristics of a system's source
water, the skill level of its operators, and other compliance
considerations will greatly impact which treatment train is
most appropriate as well as the ultimate cost of compliance.
Systems with treatment trains in place that can remove radio-
nuclides will face lower compliance costs than those without
pre-existing treatment capability. For instance, most surface
water systems already have treatment in place (coagulation or
filtration) that, if enhanced, is capable of removing uranium.

The rule lists several Best Available Technologies (BATs) for
the removal of radionuclides (see Exhibit 1).  In addition, the
rule lists  Small System Compliance Technologies (SSCTs),
which are specifically recommended for use by small systems
serving fewer than 10,000 people. When considering SSCTs, EPA looks at the affordability of the technology (since per
                                                        household costs for central treatment tend to be higher for
                                                        smaller system customers) and technical complexity (since many
                                                        small systems do not have access to well-trained water system
                                                        operators).  The SSCTs represent technologies that are affordable
                                                        and achieve compliance across the small system size categories
                                                        (25-500; 501-3,300; and 3,301-10,000 people).  For example,
                                                        reverse osmosis and ion exchange/activated alumina point-of-use
                                                        (POU) devices are viable options for small systems, especially
                                                        those serving fewer than 200 people. Both BAT and SSCT
                                                        treatment technologies must be operated in very different modes
                                                        depending on which radionuclide is being removed.
Figure 5: Percent of CWSs Using Various Treatment
Technologies and Strategies for Uranium Removal
i nno/
QAO/,
xno/.


AOA





 1  2 D3 D6








25-500 persons 501-
Population Serve








,000,000 persons
id
                                                        Figure 5 illustrates the estimated CWS compliance strategies for
                                                        uranium removal.  Despite operating difficulty, most systems are
                                                        expected to install lime softening capability. Approximately 17%
                                                        of CWSs are expected to develop an alternative water source,
                                                        while an equal number will comply through regionalization or
water blending.  About 10% of small water systems are expected to elect to comply by installing either ion exchange, activated
alumina, or reverse osmosis POU devices.  Technology
choices for radium removal are expected to mirror those for
uranium removal, except that up to 20% of CWSs will
choose greensand filtration over lime softening.

To ensure cost-effective compliance with the uranium and
combined radium MCLs, systems will need to evaluate their
treatment technology options as a first step. All other factors
being equal, systems will most likely choose the cheapest
treatment option that ensures compliance. Figure 6 illus-
trates estimated cost ranges for an average CWS serving
between 25 and  500 people that operates the technology at
30% removal efficiency. The costs are production costs per
1,000 gallons treated for both surface and ground water
systems removing either radium or uranium. These esti-
mates include costs associated with residuals handling and
disposal.
Figure 6: Representative Production Costs for CWSs
Serving Populations of 25-500 (in 1999 $ per 1,000
gallons treated)
4>O
 = High Estimate
O = Low Estimate
"t-i

*2 ?
4>.Z,

I 2/3
Treatment




I

4 5
Technologies

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HOW CAN THE DWSRF ASSIST SYSTEMS?
States use DWSRF capitalization grant monies to provide low-interest
loans to publicly- and privately-owned public water systems for
infrastructure improvements needed to continue to ensure safe
drinking water. States may offer principal forgiveness, reduced
interest rates, or extended loan terms to systems identified by the state
as serving disadvantaged communities.  States also have the ability to
reserve a portion of their grants (i.e., set-asides) to finance activities
that encourage enhanced water system management and help  to
prevent contamination problems through source water protection
measures. Based on the fiscal year 2002 appropriation of $850
million, capitalization grants ranged from $8.0 million to $82.4
million per state.  Where funding is not adequate for all  systems that
require treatment, states may choose to offer extended compliance
schedules through exemptions, where appropriate, to some systems.

Most capital projects - including adding new technologies and
upgrading existing technologies  needed to comply with the  Radio-
nuclides Rule are eligible for funding under the DWSRF (see  Exhibit
2).  Consolidation and restructuring of systems can be a cost-effective
option for small systems that are affected by the rule. The DWSRF
can fund consolidation, including situations where a system is unable
to maintain compliance for technical, financial, or managerial reasons.
POU devices will be an attractive  option to small systems because of
 .	.   cost. The DWSRF can
                                        fund these devices  as long
                                        as the units are owned and
                                        maintained by the  water
                                        system.
      Jackson, Nebraska
The Village of Jackson is a small
economically disadvantaged community
of 230 people in northeast Nebraska.
To achieve compliance with regulations
for radium-226, radium-228, and Gross
Alpha Particle Activity, the ground
water system  in Jackson developed a
$500,000 project  to install a new well
in a different aquifer, build a water
treatment plant for iron removal, and
make needed improvements to its
distribution system. The system
received a Community Development
Block Grant of $250,000 and a
$250,000 DWSRF loan  with $125,000
in principal forgiveness. With this
assistance, Jackson was able to afford
the project and complete it in the
spring of 2000.
Exhibit 2: Projects/Activities Eligible for DWSRF
T ,-.,- . Eligible Under Eligible Under
TypeofPro,ect/Act,v,ty infrastructure Fund Set-Asides
Treatment
Water Softening/Iron Removal
Ion Exchange
Reverse Osmosis
Enhanced Coagulation/Filtration
Greensand Filtration
POU Devices
Planning & Design Activities
System Consolidation
System Restructuring
Yes
Yes
Yes
Yes
Yes
Yes*
Yes
Yes
Yes
No
No
No
No
No
No
Yes**
No
Yes
System Administrative Improvements
Hire Staff
Staff Training
Public Outreach
Monitoring
Rate Increase Process
No
No
No
No
No
No
Yes
Yes
No
Yes
State Administrative Improvements
Hire Staff
Staff Training
Public Outreach
Compliance Oversight
Enforcement
Pilot Studies
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
   *Must be owned and maintained by system.
                "For small systems only.
                                        States can use set-aside funds from the DWSRF to assist systems directly as well as
                                        to enhance their own program management activities (see Exhibit 2). A state may
                                        use set-asides to make administrative improvements to the entire drinking water
                                        program, which faces increased costs in implementing the Radionuclides Rule.
                                        States can provide training to small systems on meeting the requirements of the
                                        rule as well as technical assistance in identifying appropriate technologies. In
                                        addition, states can provide assistance to small systems to cover the costs of project
                                        planning and design for infrastructure improvements.

                                        Since the DWSRF program is managed by states, project and set-aside funding
                                        varies according to the priorities, policies, and laws within each state. Given that
                                        each state administers its own program differently, the first step  in seeking assis-
                                        tance is to contact the state DWSRF representative which can be found on the
                                        EPA DWSRF website.
  FOR MORE INFORMATION...
      DWSRF and Radionuclides Rule
 DWSRF Website:
 http://www.epa.gov/safewater/dwsrf.html
  Radionuclides Implementation Website:
                                                     General Information
                                               SDWA Hotline
                                               1-800-426-4791
                                               EPA's Ground Water & Drinking
                                               Water Website:
                                               http://www.epa.gov/safewater/
Office of Ground Water and
Drinking Water (4606M)

EPA816-F-02-008

May 2002
Printed on Recycled Paper

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