United States
Environmental Protection
Agency
Steps to Selecting a Compliance Option
for the Radionuclides Rule
Step I > How Do I Get Started?
Your system has determined that it is out of compliance
with a maximum contaminant level (MCL) for one or
more radionuclides (e.g., radium 226/228, gross alpha,
uranium, and beta particles and photon emitters). To
identify a long-term compliance solution, you must
understand the extent of the problem, including how
much you need to reduce the level of radionuclides in
treated water, which contaminants are of the greatest
concern, and whether there are any seasonal fluctuations
in radionuclide levels. You will need to review past
sampling results, and possibly collect new water samples
to get this information. You may also want to contact
other water systems in your area that have successfully
complied with the Radionuclides Rule1 to learn from
their experience. Your state drinking water program will
be a good source of contacts. Many states will require
that a professional engineer be involved if treatment
changes are made or new treatment is installed. A
professional engineer may be helpful in completing the
compliance steps outlined in this brochure.
Key considerations include:
* In addition to working with your state drinking
water program, you may need to coordinate
with other state and local entities (e.g., radiation
control program) and a professional engineer.
If existing or new treatment is used to reduce
levels of radionuclides, waste disposal and worker
safety issues will need to be addressed.
Permitting may be required for non-treatment
solutions, treatment changes, and disposal of
treatment residuals.
* The above issues will increase the amount of time
that it takes to implement a compliance solution
and achieve compliance.
Once you have assessed your compliance problem,
the next steps are to evaluate your options and
develop a plan.
Steps to Compliance
Conduct quarterly sampling for initial monitoring2 or after routine result exceeds MCL
If running annual average of quarterly samples exceeds MCL, or one sample result causes MCL violation
Contact state to review options for compliance
Evalulate non-treatment and treatment options
Consider compliance costs and financing options
1 The Radionuclides Rule applies to all community water systems. Go to http://www.epa.gov/safewater/radionuclides for more detailed information.
2 Or use historical quarterly sampling data where allowed by the state.
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Step 2 y What Are My Non-Treatment Options?
While installing new treatment is an important
option to consider, the following non-treatment
approaches may be simpler, more economical
compliance solutions in the long-term.
Find a Better Source of Wbter
You may be able to find (or create) another, higher
quality water source to replace the existing source.
However, some systems may find it difficult to locate
a nearby source that is not influenced by naturally
occurring radionuclides. Be sure to contact your state
drinking water program since new source approval
and/or permits are typically required.
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Key considerations include:
The contaminated source could be abandoned or
other sources (e.g., standby or emergency sources)
could be used for blending or as permanent
replacement sources.
Water-bearing fractures with high radionuclide
levels in the existing well could be selectively
sealed off, but this may be expensive.
There are alternate sources that comply with all
regulations, or that could be treated to remove
any other existing contaminants at a lower cost
than radionuclide treatment (state approval may
be necessary before choosing this option).
The new source will provide enough water to meet
system demand and is located within a reasonable
distance from the current system.
Blend Source Winters
Blending involves mixing waters from two or more
different sources prior to distribution. At its simplest,
a source with high radionuclide levels is blended with
a source with radionuclide levels below the MCL to
produce water that is within the limits of the MCL
or a safe margin below the MCL. Check with your
state's drinking water program before investigating
this option, as blending is not permitted in all states.
Key considerations include:
The availability of other sources with radionuclide
levels below the MCLs that can be blended with
existing sources. This could include obtaining
water from a nearby water system.
The cost of blending sources.
Whether it is possible to blend the sources so that
the MCLs are met at every entry point to the
distribution system (EPTDS) while maintaining
all required plant flow rates.
Whether it will be necessary to replace pumps or
take other measures to ensure that the blended
water is in compliance.
The impact of combining sources on water
quality in the distribution system (e.g., changes
in finished water quality parameters [such as pH
and corrosivity] may affect piping and create
compliance problems with other regulated
contaminants [such as lead]).
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Step 2 continued
Interconnect or Consolidate
Another option is interconnecting with and/or
purchasing water from another water system or
consolidating all aspects of system operation to
become a single, larger system.
Key considerations include:
Whether there is a nearby system meeting the
requirements of the Radionuclides Rule that is
willing to interconnect or consolidate (check with
your state's drinking water program).
The costs of interconnection or consolidation.
The nearby system's ability to handle increased
demand from additional customers.
The impact of the combined sources on water
quality and the distribution system.
For more information:
* Volumes I and II of EPA's System Partnership
Solutions to Improve Public Health Protection
guide, available on-line at http://www.epa.gov/
safewater/smallsystems/managementhelp.html.
EPA's Restructuring and Consolidation of Small
Drinking Water Systems: A Compendium of State
Authorities, Statutes, and Regulations, available on-
line at http://www. epa.gov/safewater/smallsystems/
compliancehelp. html.
Your state may also be able to provide additional
assistance by coordinating with other organizations:
Local American Water Works Association
(AWWA) section (http://www.awwa.org/awwa/
sections/seccont. cfiri).
State Rural Water Association (RWA) affiliate
(http://www. nrwa. org/sa. htm).
Local Technical Assistance Center (http://www.
tacnet.info/).
Step 3 } Can I Use Existing Treatment to Remove Radionuclides?
If non-treatment options are not available or
practical, the next step is to consider whether you
can modify existing treatment (if available) to
remove radionuclides while continuing to meet
the original goal of treatment. For example, if your
system is currently using lime softening, it may be
possible to modify the treatment to remove radium.
Some treatment technologies for iron and manganese
removal and arsenic removal may also achieve some
radium and uranium removal, respectively. Point-
of-entry (POE) water softener systems will remove
radium and could be modified to remove uranium
by adding a small amount of anion resin (see the
case study on page 4 for more information on using
POE devices to treat for radionuclides). You should
consult with your state drinking water program to
determine whether or not the use of POE devices to
comply with an MCL is allowed.
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Step 3 continued (Existing Treatment to Remove Radionudides)
Evaluating existing treatment should involve raw
water monitoring and a careful consideration
of how the presence of other contaminants will
impact treatment effectiveness, contaminant
levels (including radionuclides) in treated water,
potential impacts of concentrating radionuclides
in filters and residuals, and disposal options
including possible regulatory concerns (see Step 4
for more information). EPA has also developed an
informational poster and various guides that can
help you better understand these issues http:llwww.
epa.gov/safewater/radionuclides/compliancehelp.html.
Step 4 J How Do I Choose the Most Appropriate Treatment?
If you have ruled out non-treatment options or
treatment modification, the next step is to begin
evaluating treatment technologies. The type of
treatment to consider will be based upon the
compliance problem (i.e., radium, uranium, or the
combination of both). Possible treatment options
include ion exchange, reverse osmosis, activated
alumina, coagulation/filtration, lime softening, and
pre-formed hydrous manganese oxide (HMO)
filtration. Ion exchange is one technology used most
frequently by small water systems for radionuclide
removal; however, there are trade-offs that must be
considered in using this technology including higher
radiation levels in the filters, and the potential need
and associated costs of disposing of the filters in
special regulated landfills. Throw-away media that can
be removed by the treatment vendor or a licensed
waste broker, or disposed of in an approved landfill
may also be an option for small systems.
(,
A CASE STUDY
Illinois' POE Treatment Program for Radium
Three small water systems in Illinois successfully
installed POE water softener devices to treat for
radium. Working with the U.S. EPA, the Illinois
Environmental Protection Agency (IEPA) developed
guidelines and criteria for testing the devices to ensure
their effectiveness. The water systems are responsible
for all aspects of treatment operation, and the POE
units are equipped with sensors that alert customers to
the need to change the media or any other operational
problems. For one of the systems, the total 10-year
cost of the POE program ($475,000) was nearly half
that of the next-cheapest option (centralized ion
exchange treatment, at $920,000), and less than one-
third the cost of installing centralized reverse osmosis
treatment ($ 1.6 million).
Some technologies may be more or less appropriate
considering system size and location, average
demand, the levels and types of radionuclides in the
source water, disposal options, capital and operation
and maintenance costs, and operator expertise. A
number of these considerations are presented in
this step. You should work closely with your state's
drinking water program to evaluate your treatment
options, as they may have restrictions on using
certain treatment technologies (e.g., POE devices)
or disposal options for drinking water treatment
residuals. Your local landfill and wastewater
treatment plant (WWTP) should be contacted
regarding disposal options.
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Step 4 continued
More detailed information on the various treatment
technologies is available on-line at http:llwww. epa.gov/
safewater/radionuclides/compliancehelp.html.
Step 4a - Residual Disposal Options
The availability and cost of residual disposal options
are critical factors in determining which treatment
options are realistic and how the treatment will be
operated once it is installed.
Some water systems, such as small rural systems, may
have very limited residual disposal options due to
location, size, and resource limitations.
Liquid Residuals
Liquid residuals include wastes such as brine,
backwash water, and rinse water. The most common
methods for liquid residual disposal include direct
discharge to a water body or discharge to a WWTP
which is regulated by National Pollutant Discharge
Elimination System (NPDES) permits at the state
level. For more information see http:llcfpub.epa.
gov/npdes/. Some water systems may also be able
to dispose of liquid residuals in underground
injection wells. If liquid residual disposal options are
limited, there are treatment technologies that do not
generate significant quantities of liquid waste. Key
considerations include:
Whether residuals can be discharged to a WWTP
or directly into a water body.
Restrictions on discharge, including local
(e.g., county) and state limits on contaminant
concentrations. The U. S. Nuclear Regulatory
Commission (NRC) may have additional
restrictions for uranium. For more information see
http-.llwww. nrc.gov.
Whether underground injection is an option,
and if so, whether the residuals will be classified
as radioactive or hazardous. Contact your UIC
program staff for assistance at http://www.epa.gov/
safewater/uic/primacy. html.
Whether intermediate processing (e.g., dewatering)
could be used to create other (solid residual)
disposal options.
Solid Residuals
Solid residuals include wastes such as spent media
from a throw-away process and sludge from processes
like lime softening, coagulation/filtration, and HMO
filtration. Occasionally, aged filtration media and ion
exchange resins must be replaced and these residuals
may also contain some level of radiounuclides.
While some states may allow sludges from lime
softening to be applied on agricultural land, most
solid residuals are generally disposed of in landfills
or special Low Level Radioactive Waste (LLRW)
facilities, if the concentrations of radionuclides are too
high. The amount and concentration of contaminants
in solid residuals, as well as your system's location,
transportation options, and cost, will influence where
and how the wastes can be disposed. For a list of
municipal landfills and LLRW facilities, see EPA's
Web site at http://www.epa.gov/safewater/radionuclides/
compliancehelp. html.
Key considerations include:
Aged filtration media and resins can be cleaned
or regenerated, respectively, on site to minimize
the level of contamination of the media or resin.
In these cases, analysis of the solids should be
considered to determine the classification of the
solids for disposal.
The estimated levels of contaminants in the waste.
(Your state or a professional engineer may be able
to assist you with developing these estimates.)
Whether these levels will cause the waste to be
classified as a low-level radioactive waste, hazardous
waste, source material, or mixed waste. If the
treatment process residuals generated exceed
regulatory concentration limits, it may result in the
need for a state radiation control agency or NRC
license (for uranium) of the system.
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Step 4 continued (Solid Residuals)
The option of hiring a waste broker, or arranging
with the treatment vendor to collect and dispose
of the wastes. For more information on waste
brokers operating nationwide, see the National
Directory of Brokers and Processors at http://
bpdirectory. com/.
For more information:
EPA's A System's Guide to the Management of
Radioactive Residuals from Drinking Water
Treatment Technologies, available on-line at
http://www.epa.gov/safewater/radionuclides/
compliancehelp. html.
The American Water Works Association Research
Foundation's (AwwaRF's) Management of the
Disposal of Radioactive Residuals in Drinking Water
Treatment, AwwaRF (Final report for Project
#2695, 2005).
Step 4b - Raw Water Monitoring
A review of raw water monitoring results will provide
a comprehensive understanding of water quality
characteristics.
This is important for several reasons:
To identify any competing ions that could limit
treatment effectiveness or cause taste or odor
problems in treated water.
To identify other contaminants that could be
removed along with radionuclides (e.g., nitrate,
arsenic, hardness, or iron), thus improving the
quality of treated water and avoiding other
compliance problems.
To estimate the potential concentration of
contaminants in the liquid and solid wastes (or
residuals) that treatment may produce.
Step 4c - Treatment Evaluation Criteria
The next step is to work with your state or
professional engineer to determine the criteria that
you will use to evaluate treatment options. These may
vary from system to system based on your system's
characteristics and priorities.
Key considerations include:
* The level of radionuclides you would like to
achieve in finished water.
* The quantity and characteristics of the residuals
and on site disposal options.
The availability of land for building and
installing treatment.
The levels of water loss that will be tolerable given
water quantity issues.
The capacity (flow rate) for which the treatment
will be designed.
Your system operator's level of experience and
the operator skill level and certification required
to operate the treatment technologies that you
are considering.
Whether the state has any additional requirements
that will impact treatment options (e.g., increase
costs, impact targeted finished water radionuclide
concentrations, or limit residual disposal options),
or require the facility to be licensed by the state
radiation control agency or NRC.
For more information on selecting treatment
and treatment technologies, see EPA's
Web site at http://www.epa.gov/safewater/
radionudides/compliancehelp.html.
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Step 5 J How Can I Pay for the Costs of Compliance?
The costs for finding, designing, installing, and
operating treatment can be significant. Estimating
costs before investing in treatment can help you
avoid unexpected expenses and develop a plan for
covering all costs. When estimating capital and
operations and maintenance (O&M) costs, you
should consider several key expenses associated
with treatment installation (or modification) and
operation.
Some are one-time expenses:
Pilot testing, if required by the state.
Professional engineering fees.
Permitting.
Training costs including radiation protection
training (i.e., operators).
Engineering design and construction costs
(including any costs for purchasing additional
land and building(s) to house the treatment
sysem).
Equipment and installation costs.
Monitoring instrumentation costs.
Regulatory licensing costs.
Other expenses will be recurring:
Chemical and chemical storage costs.
Energy costs for operating the treatment unit and
any associated facilities.
Labor costs (i.e., if additional operators or an
operator with more experience is required).
Costs of compliance monitoring and any
additional routine monitoring done to ensure
that the treatment is operating properly, based on
the monitoring schedule established by your state
drinking water program.
If applicable, the cost and frequency of media
replacement and media disposal.
Residual handling, transporting, and disposal
costs.
Regulatory licensing costs.
Recordkeeping costs.
Keep in mind that some treatment options which
require a significant up-front investment, may
turn out to be more affordable in the long-term,
especially when compared to the cost of not
installing treatment and responding to a more serious
compliance problem in the future.
While systems may seek to incorporate the longer-
term costs of operating and maintaining treatment
into water system rates, there are also many sources of
low-cost or no-cost financing that may be available to
help systems with all aspects of treatment selection,
installation, and operation, including EPA's Drinking
Water State Revolving Fund (DWSRF).
For more information:
EPA's fact sheet on "Using the DWSRF to
Comply with the Radionuclides Rule," available
on-line at http://www.epa.gov/safewater/dwsrff#facts.
EPA's "Sources of Technical and Financial
Assistance for Small Drinking Water Systems"
guide, available on-line at http://www.epa.gov/
safewater/smallsystems/financialhelp.html#resources.
EPA's "Setting Small Drinking Water System Rates
for a Sustainable Future" guide, available on-
line at http://www.epa.gov/safewater/smallsystems/
financialhelp. html#resources.
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There are numerous non-treatment and treatment compliance options that water systems can consider for
compliance with EPA's December 2000 Radionuclides Rule. The best option for your system will depend on your
system's unique characteristics. Close communication and cooperation with your state drinking water program
throughout the decision-making process will ensure that you are fully informed of your compliance options,
regulatory requirements, and opportunities for funding.
Checklist of Recommended Considerations
Have you:
0 Considered using a professional engineer?
0 Coordinated with the appropriate state and local
agencies?
0 Reviewed or collected water quality data?
0 Considered non-treatment options?
0 Considered the use of existing treatment?
0 Studied options for new treatment?
0 Identified a method for waste disposal?
0 Obtained necessary permits?
For More Information
EPA's Safe Drinking Water Hotline 1-800-426-4791 (M-F, 10am - 4pm)
http-.llwww. epa.gov/safewater/radionuclides/index. html.
Office of Water
www.epa.gov/safewater
EPA816-F-08-010
June 2008
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