United States
          Environmental Protection
          Agency
Office of Water
(4606)
EPA816-D-00-002
December 2000
oEPA  Implementation Guidance
          for Radionuclides
                                 EPA Headquarters Library
                                  Mail code 3201
                               1200 Pennsylvania Avenue NW
                                Washington DC 20460

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 Table of Contents
Introduction	 vii



Section I.     Rule Requirements  	  1
        A.     Executive Summary	:.^f-:	  3
        B.     Key Dates of the Rule 	\	  7
        C.     Rule Summary	  9
              C.I     Background	-<^.:.	  9
              C.2     Record  Keeping  	T.'	jpi.^....^^	  9
              C.3     Reporting  	"	rkv	 10
              C.4     Monitoring for Gross Alpha, Radiura-226, Radium-228, andUiniffiimv..... 11
              C.5     Monitoring for Beta Particle and Photon Radioactivity	••*-'...,;'	 20
              C.6     Grandfathered Data	 vS	'.";	 23
              C.7     Monitoring Waivers	'';,:. •	 23
              C.8     Requirements for New Systems/Sources .;;.•;:..	 24
              C.9.    Laboratory Methods	'"^'..	£!*	 24
              C.30   Treatment Technologies	,	 30
              C. 11    Variances and Exemptions  ...........	;	 34

•                                        •:-:'"'       	'  '--,!.'.ti?: •.  '
Section II.    SDWIS Reporting, Violation Determination, anitiS^fC Definitions	  1
        A.     SDWIS Reporting  	: 7	  3
        B.     Violation Determination  	  4
              B.I     Violation/Compliance Determination for Gross Alpha, Radium-226/228, and
                      Uranium	 4
              B.2     Violatiwi/pDrnplianceipfttermination for Gross Beta and Photon Emitters.... 4
        C.     SNC Definitions ^	 v:.	  6


Section III.   Primacy Revision AftpKcations	  1
        A.     StatePriniacy ProgranlRevision	 3
              A. 1     Tte Revision Process	 4
              A.2     T&$ Final Review Process   	 6
        B.     State Primacy Program Revision Extensions	  7
              B.I     The Extension Process  	  7
              B.2     Criteria that an Extension Request Must Meet	  7
              B.3     Conditions of the Extension	  7
        C.     State Primacy Package	 10
              C.I     The State Primacy Revision Checklist (40 CFR 142.10)	 10
              C.2     Text of the State's Regulation  	 11
              C.3     Primacy Revision Crosswalk  	 11
              C.4     State Reporting and Recordkeeping (40 CFR 142.14 and 142.15) 	 11
              C.5     Special  Primacy Requirements (40 CFR  142.16)	 11
              C.6     Attorney General's Statement of Enforceability  	 11
              C.7     Variances and Exemptions	 11
        D.     Guidance for Special Primacy Requirements  	 14
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December 8, 2000

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 Section IV.    Otber Resources and Guidance	  l
       A.      Fact Sheet	  3
       B.      Question and Answers	  7
Appendices

Appendix A   Violation Table for Data Management and Enforcement Purposes  .....£?.•	A-l
Appendix B   Sample Extension Agreement	.';	 B-l
Appendix C   Primacy Revision Crosswalks	 v ft	»;... j^-ife	 G-l
                                                                         , . '* JK2*.~ •
                                                                          ' '' •" ?• .
Appendix D   SDWIS-Fed DTP Reporting Requirements Guidance	I; i^vC	D-l
                                                                          '•••"$*$&:.'::•.••
                                                      ••• •.!•,-..,.,' '              ""feft1,: :• ;.•
Appendix E   Statement of Principles— Guidance on Audit'litelssues	"':•'•:	 E-l
                                                        ... "•-.,-') •
                                                        •  -*'',• "<
Appendix F   Rule Presentations	 .,»-. »...„.,	 G-l
                                                   «•       *'' ; 'S*. "" ' "l-x%\".
                                                           "': :•"•:•, 'il|i;'.
Appendix G   Rule Language	,	 h..	 H-l
Appendix H   Comparison of Derived Values

References
Emitters^:	1-1
List of Tables
Table 1-1: MCLs and MCLGs formulated Radionuclides	1-4
       ."     * •-{'..
Table 1-2: Be&Avaiteble Technol^^for Complying with the MCLs for Radionuclides	1-6
Table 1-3: Publfc^WiSp^^tern Tii^^iSfeiii|r the Radionuclides Requirements	1-7
Table 1-4: StanaardHestfiiBffects Larjjpage for CCR and Public Notification	Ml
Table 1-5: Monitoring FTGejapucaB$/QT Gross Alpha, Uranium, and Radium-226/228	1-15
Table 1-6: Monitoring Frequencies for Beta Particle and Photon Radioactivity	1-21
   *
Table 1-7: Analytical Methods Approved by EPA for Radionuclide Monitoring of Drinking Water
  : "•   (40 CFR 141.2S)i	1-25
Table 1-8: Sample Handling, Preservation, Holding Times and Instrumentation	1-27
Table 1-9: Required Regulatory Detection Limits for the Various Radiochemical Contaminants
       (40CFR 141.25)	1-30
Table 1-10:  BATs for Radionuclides in Drinking Water	1-31
Table 1-11:  List of Small Systems Compliance Technologies for Radionuclides and Limitations of
       Use 	1-32
December 8, 2000
             Radionuclides Guidance

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Table 1-12: Compliance Technologies by System Size Category for Radionuclide NPDWRs
       (Affordability Not Considered, Except for Uranium, Due to Statutory Limitations)  	1-33
Table II-1: Revised Radionuclides Final Rule Federal Reporting Violations	 II-3
Table III-l: State Rule Implementation and Revision Timetable for Radionuclides Rule	III-3
Table III-2: Extension Request Checklist	IH-9
Table III-3: State Primacy Revision Checklist	111-10
Table III-4: Example of Attorney General Statement	111-12



List of Figures	•    ./,;,_

Figure 1-1: Radionuclides Monitoring Within the Standardized Monitoring Framework. .'"'-^	1-8
Figure 1-2: Initial Monitoring Scenario for New Systems or Soutcip^Of Existing Systems without
       Grandfathered Data	 1>	1-16
Figure 1-3: Initial and Reduced Monitoring Requirements for Gross Alpha, Radium 228, Combined
       Radium 226/228, and Uranium	 .i;	1-17
Figure 1-4: Gross Beta Monitoring Requirements	1-22
Figure III-1: Recommended Review Process for State Request for Approval of Program Revisions . III-5


List of Illustrations    	

Illustration 1-1 	v	1-12
Illustration 1-2 ,v;..		;•&•	1-13
Illustration J-3	1-13
Illustration 1-4 4;:,	:j|\	1-14
Illustration T-5	1-23
Illustration 1-6 	J;	V."	1-24
Illrfstration II-l	 II-5
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Regional Contacts
Region I
Stan Rydell
617-918-1637

Region II
Robert Poon
212-637-3821

Region III
Barbara Smith
215-814-5786

Region IV
Thomas DeGaetano
404-562-9479

Region V
Miguel Dei Toral
312-886-5253
            vvEPA
Region VI
Kim Ngo
214-665-7158

Region VD
Stan Callow
913-551-7410

Region Vffl
David Robbins
303-312-6274

Region IX
Bruce Macier
415-744-1S84

Region X
Gene Taylor
206-553-1389
Radionuclides Guidance
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Introduction
The purpose of this guidance manual is to provide assistance to EPA, States, and community water
systems (CWSs) during the implementation of the Radionuclides Rule. This rule was published in the
Federal Register on December 7, 2000 (65 FR 76708). This document does not substitute for EPA's
regulation nor is this document regulation itself. Thus, it cannot impose legally-binding requirements on
EPA, States, or the regulated community, and may not apply to a particular situation based upon the
circumstances.

This manual was developed through a workgroup process involving Regions, States, and'Stakeholders,
and contains the following sections:                                    Y    v'?j
                                                           • • „
Section I summarizes the Radionuclides Rule and presents timelines
                                                                                 this rule.
Section II addresses violation determination and associated reporting requirements^ osllliffimg a violation
table to assist States in their compliance activities. Section U£ covers State'Primacy %Js^ittB.:r  :; ;
Requirements, including a timeframe for application reviewsand approval. This section4lillbontains
guidance and references to help States adopt new special primacy requirements included m-this rule.
Section IV contains a series of "stand alone" guidance materials thappll help States and PWSs comply
with the new requirements.                                    ;

The Appendices of this document provide information that will be useful tolStates^and EPA Regions
throughout the primacy revision application process. Appendix A contains a Violation table arranged for
data management and enforcement purposes. Appendix B contains the sample Extension Agreement
between EPA and the States that will allow States and EPA to docuffieat how they will share rule
implementation responsibilities if the State does not submit a primacy application by the deadline.
Appendix C contains the primacy revision crosswalks for the rule. Appendix D contains the State
reporting guidance. Appendix E is EPA's Statement of Principles on the effect of State audit
immunity/privilege laws on enforcement authority for federal programs. Appendix F contains training
presentation materials for each rule. Appendix G is a copy of the final Radionuclides Rule and Appendix
H includes acepy of the betaandphoton emitter conversion tables.


EPA and State decision makers retaio|be discretion to adopt approaches on a case-by-case basis that
differ from this guidance where appjrofWiate. Any decisions regarding a particular facility will be made
based on the applicable statutes and regulations. Therefore, interested parties are free to raise questions
and objections abouttheiappsfiriateness of the application of this guidance to a particular situation, and
EPA will consider whether or act the recommendations or interpretations in the guidance are appropriate
in that situation.  EPA may change this guidance in the future.
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Section I.
Rule Requirements

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I-A.    Rule Executive Summary - Radionuclides Rule

Purpose	.^___

The purpose of this summary is to acquaint State decision-makers and other public health officials with
the final rule for (non-radon) radionuclides in drinking water. The Radionuclides Rule was published in
the Federal Register on December 7, 2000 (65 FR 76708). The rule is applicable to CWSs and includes
requirements for uranium, which was not previously regulated, and revisions to the monitoring
requirements for combined radium-226 and radium-228, gross alpha particle radioactivity, and beta
particle and photon radioactivity.  The rule retains the existing MCLs for combined radium-226 and
radium-228, gross alpha particle radioactivity, and beta particle and photon railioactiyity. Exposure to
radionuclides from drinking water results in the increased risk of cancer. The uranium standard will
protect drinking water customers from uranium levels that may cause toxic efiects to:tac-kidney and will
reduce cancer risk.                                                  ;••'      • "lifer.:.  •
                                                                 f         "::5rfw:*;
                                                                            'A'' ( •_
Background                                              ;

Regulations for radionuclides in drinking water were first promulgated!!! 1976 as interim regulations
under the authority of the Safe Drinking Water Act (SDWA) of 1974..StaBda»ds were set for three groups
of radionuclides: beta and photon emitters, radium (radium-226 and radium-218), and gross alpha
radiation. These standards became effective in 1977. The 1986 SDWA Amendments added radon and
uranium to the list of regulated radionuclides and required EPA to promulgate a revised radionuclide rule
by June 1989. When EPA did not meet this deadline an Oregon plaintiff brought suit to require EPA to
issue regulations. EPA entered into a series of consent agreements whicn set a schedule for the issuing
the non- radon radionuclide regulations by November 21, 2000.   „;

In 1991, EPA proposed new regulations for uranium and radon and revisions to the existing radionuclides
regulations. This proposal was not promulgated as a final rule. The revised consent decree (mentioned
above) required an action with respect to the final (non-radon) regulation by November 21, 2000. To
meet this deadline, EPA published aNotice of Data Availability (NOD A) in April 2000, which informed
the public am) die regulated community of new information concerning  radionuclides in drinking water.
The revised (non-radon) Radionaclides Rule, published on December 7,2000 satisfies the requirements
of the consent "decreed 5

Benefits of the Radionuclides Rule	

This^rule promulgates new monitoring provisions that will ensure that all customers of community water
systems will receive water-that meets the Maximum Contaminant Levels for radionuclides in drinking
water. Under the 1976 rule, water systems with multiple entry points to the distribution system were not
required to test at every entry point, but rather to test at a "representative point to the distribution
system." While the 1976 requirement did ensure that the "average customer" was protected, it did not
ensure that all customers were protected. Under the new rule, all entry points will be tested and all CWS
customers will be ensured of receiving water that meets the MCLs for radionuclides in drinking water. In
addition, this requirement is more consistent with the monitoring requirements for other comparable
drinking water contaminants.

The new standard for uranium in drinking water will result in reduced uranium exposures for 620,000
persons. The uranium standard will protect drinking water customers from uranium levels that may cause
toxie effects to the kidney and will reduce cancer risk. The kidney toxicity benefits for the uranium
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1-3
December 8. 2000

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standard can not be quantified because limitations in existing health effects models at levels near the
MCL. In addition to these non-quantified kidney toxicity benefits, 0.8 cancer cases per year are expected
to be avoided, with estimated monetized cancer health effects benefits of $ 3 million annually. Water
mitigation for uranium also removes other contaminants, which has associated benefits.

In addition, the new rule promulgates separate monitoring requirements for radium-228, which is
expected to reduce exposure to 420,000 persons and result in the avoidance of 0.4 cancer cases per year,
with estimated monetized health effects benefits of $2 million annually. Water mitigation for radium also
tends to reduce iron and manganese levels and hardness, which also has significant associated benefits.

Applicability and Compliance Dates                           ..;•.'.     jf

The Radionuclides Rule applies to all community water systems {CWSs) (4^C3FR,i^i''L26). The
regulations do not apply to noncommunity water systems.

The effective date of the Rule is December 7,2003 (40 CFR §141.66(0). Systems
accordance with a State specified plan, between the effectiveid^^lirf December 31,
use grandfathered data(40 CFR § 141.26(a)( 1)).           ;  '• ff'"'"

Maximum Contaminant Levels (MCLs) and Maximum;
(MCLGs)
                                                                    inant Level Goals
                                                        and retains the existing MCLs for
The revised Radionuclides Rule promulgates
combined radium-226/228, gross alpha particle, and betJLparticli^O|plpton radioactivity. The Rule also
finalizes MCLGs which are shown in Tablet- 1 (40 CFR §141.515). '
             Table 1-1: MCLsdrad MCliGs for Regulated Radionuclides
Regulated Radwmociide
• .;. ''••>,., • •' -a- •
Beta/pho^
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Monitoring

The standardized monitoring framework for radionuclides is complex, in part, because of the inter-
relationship of the analytes; i.e., the alpha emitters, radium-226, and uranium contribute to gross alpha
activity. A detailed discussion on the monitoring requirements is included in Sections I.C.4 and I.C.5 of
this document.

Grandfathered Data and Monitoring Waivers

Systems may not use grandfathered data to satisfy the monitoring requirements for beta-anrf photon
emitters (40 CFR § 141.26(b)). However, States may allow data col lected between June.2000 and
December 8, 2003 to be used to comply with the initial monitoring requirements fer'gross alpha, radium-
226/228, and uranium (40 CFR §141.26(a)(2)(ii)). A detailed discussion abputgram^ithermg of data can
be found in the Section I.C.6 of this document.                          -  ;
                                                                                    ve the final
                                                                                    ^sampling
                                                                                       See
States cannot issue monitoring waivers under the Radionuctide Rule. Htwever, States'
two quarters of initial monitoring for gross alpha, uranium. radium;22j6, and radium-2
results from the previous two quarters are below the detectioa|liaiii-iffi^.O CFR §141.26(a
Section I.C.7 of this document for more detail on waiving of raoBiSl^i|:i:equirments.

Requirements for New Systems/Sources                        j
                                                    •••.          'i;;       -'  '">
New systems and systems that begin using a new source of supply must conduct initial monitoring for
gross alpha, radium-226/228, and uranium the quarter after initiating use of the new supply (40 CFR
§141.26(a)(l)(ii)).  A detailed discussion along with an annotated example is included in Section I.C.8 of
this document.

Laboratory Methods

Many testing procedures for regulated radionuclides were approved in 1976 and many additions or
changes to analytical methods were included in the proposed 1991 Radionuclides Rule. EPA approved 66
radiochemical methods in the March 5,1997 radiiomtclides methods rule (62 FR 10168,40 CFR
§141.25). Currently, 89 radiochemical methods are approved for compliance monitoring of radionuclides
in drinking water. These methods and various quality control requirements are detailed in the Section
I.C.9 of this document

Treatment Technologiesjautd Costs

EPA.has evaluated several technologies for removing radionuclides from drinking water. Details on
EPA-'s review of the 1999^draft of "Technologies and Costs," the EPA 1998 radium compliance cost
study, the 1998 Federal Register notice of "Small Systems Compliance Technology Lists", and the
November, 2000 Radionuclides Economic Analysis which provides national costs are included in Section
I.C.10 of this document.  Table 1-2 provides a summary of the  Best Available Technology (BAT) for
complying with the MCLs for combined radium 226/228, gross alpha, beta particle and photon
radioactivity, and uramium.
        'Regulatory detection limits are defined in 40 CFR §141.25(c).
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December 8, 2000

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      Table 1-2: Best Available Technologies for Complying with the MCLs for
                                       Radionuclides
Contaminant
Combined radium-226/228
Gross alpha (excluding radon and uranium)
Beta particle and photon radioactivity
Uranium
BAT
Ion Exchange, Lime Softening, Reverse Osmosis
Reverse Osmosis
Ion Exchange and Reverse Osmosis x^
Ion Exchange, Lime Softattiagijieverse Osmosis,
bnnanced Lp^ulatiorur-raraiipo
* Assumes that the system already has coagulation/filtration in place.

Cost information is available in an Appendix to the 1999 "Technologies.*!*} Costs'
1998 radium compliance cost study. The cost study gatherejfrldata from 29 systems in
costs of different technologies. Reverse osmosis was the moSt;€XpM|SJve technology ide:
exchange was one of the least expensive.
                                                                                    compare
                                                                                  ,and ion
Variance and Exemptions
                                                                  I
Small System Variances -  Small system variances aw aBNniiiable for anyjeeiitaminant regulated under
the Radionuclide Rule because EPA has identif^affbrdWfewnaU system-compliance technologies. See
Section I.C.10 for a summary of small systen^^npliance^eiEiijpp|^|.iBieluding a table that summarizes
the compliance technologies by system sizeaiiitegory.      s  V'"TsM|P:

General Variances - All systems are,jeBgibIe for general variances from the MCLs for gross alpha,
combined radium-226/228, uraniun^iind beta particle and photon emitters. However, a system must meet
the requirements in § 1415(a) of SBfSpA to quajpir for a general variance.

                                    periojpiiiBie'-years from the effective date of the MCLs, and
                                   romulgafed in 1976 for gross alpha, radium-226/228, total beta
                                       period has expired. The Agency has promulgated a new
                                       i. issue an exemption to a PWS for the uranium MCL if the
                                   I §1416.
Exemption•-: -site maximiah
since EPA Miainied the existing
particle and^^TOKemitters, the1
regulation for ircaniuDVlherefQre,
system meets thedCritttat^Bed in S
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Radionuclides Guidance

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I-B.    Key Dates of the Rule
The effective date for the revised Radionuclides Rule is December 7, 2003. The current Rule remains in
effect until this date. Under the revised Rule, all CWSs are required to complete the initial monitoring
requirements by December 31, 2007 (40 CFR § 141.26). A system that collects samples for gross alpha,
radium-226/228. and uranium contaminants between June 2000 and December 8, 2003 may be able to
grandfather this data and therefore may not have to conduct initial monitoring (40 CFR § 141.26(a)(2)(ii).

Systems must monitor, in accordance with a State specified plan, between December 7, 2^03 and
December 31,2007. This will synchronize radionuclides monitoring with thejjtondardjaisid monitoring
framework (specifically Phase 1I/V organic and inorganic monitoring), and taiSlJeviate^potential
laboratory capacity problems. Systems will be able to collect radionuclide saiBjriesin conjunction with
the inorganic, synthetic organic, and volatile organic contaminant samples  wii|Ji5nuits|,be collected by  -
December 31,2007.                                                       ;^i:

A timetable of key dates, and a time line illustrating the radionuclides monitoring requirements within
the standardized monitoring framework are presented in Table 1-3 and Figure 1-1, respectively.
   Table 1-3: Public Water System Timetable for the:
                   luclides Requirements
Date
July 9, 1976
July 18, 1991
April 2000
June 2000
December 7, 2000
December 7, 21302
December 7, 2005 • :lfl
December 7, 2003
t
December 7, 2004
December 3 1, 2007
Radionuclides Requirements
,-t • . •• ",-K » • --. =».v^. .-
Radionuclides Drinking-water-Regulation Final Rule
Revised Radionuclides Proposed Rule V3
Revised Radionuclides Notice of Data Availability (NOD A)
Data collected between June 2000 and December 8, 2003 may be eligible
for use'fls grandfathered data to satisfy the initial monitoring requirements
for gross alpha, radium-226/228 and uranium. (Note: The use of
gradtfethered data is at the States discretion.)
';*".;• '
Revfeft^Radionuclides Final Rule
„«•!*. sEs ~ -.. . :
*,*'""*'", :'
State primacy revision application package due
Rule effective date
Systems must begin initial monitoring under a State specified monitoring
plan unless the State permits the grandfathering of data collected between
June 2000 and December 8, 2003.
State primacy revision application package due for those States requesting
2 year extensions
All systems must complete initial monitoring
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 I-C.     Rule Summary - Radionuclides Rule

 I-C.l     Background

 Regulations for radionuclides in drinking water were first promulgated in 1976 as interim regulations
 under the authority of the SDWA of 1974. The standards were set for three groups of radionuclides: beta
 and photon emitters, radium (radium-226 and radium-228), and gross alpha radiation. These standards
 became effective in 1977.

 The 1986 SDWA Amendments identified 83 contaminants for EPA to regulate, includijigthe regulated
 radionuclides, which lacked an MCLG, and two additional radionuclides, uranium and radon. The
 Amendments also declared the 1976 interim standards to be final National.fi^^ayjlbrinking Water
 Regulations (NPDWR). The 1986 SDWA Amendments provided A'Statutory;4^HG^j)romulgate a
 revised radionuclide rule by June 1989.
 When EPA failed to meet this statutory deadline, an Oregoo|flaintiff brought suit to fei|Bii*pES?po issue
 the regulations. EPA entered into a series of consent agreements setting a schedule for issuing the
 regulations for non-radon radionuclides.
                                                             '*X
 In 1991, EPA proposed new regulations for uranium and radon, as welllaSj.revisions to the existing
 regulations. The proposal included the following features; (1) an MCLO^faaii&fo/ all ionizing radiation;
 (2) revised MCLs for beta particle and photon radioactivity, radium- 226, radilS-228, and gross alpha
 emitters; (3) proposed MCLs for uranium and radon; and (4) revisions to the categories of systems
 required to monitor, the monitoring frequencies, and the appropriate screening levels. EPA received
 comments on the new data and regulatory options presented mitlwl99l:;proposal. However, the proposal
 was never promulgated as a final rule, in large part, because of controversy surrounding the proposed
 MCL for radon.

 In accordance with the consent decree, EPA agreed to publish a final action with respect to the proposed
 regulation for uranium by November 21, 2000. EPA also agreed to either take final action by the same
 date with respect to radium, beta/pboton emitters, and alpha emitters or publish a notice stating its
 reasons for not taking  final action;onihe proposal. The 1996 Amendments also directed the Agency to
 withdraw the proposed MCL for w|^ which was done on August 6, 1997 (62 FR 42221) and provided
 a framework foranUkai^pecific regulation.

 I-C.2     Record Keeping

 The standard record keepingiequirements for PWS monitoring programs apply to the Radionuclides
 Rule ( 40 CFR §141.33 forCWS requirements and 40 CFR §142.14 for State requirements).

 CWSs must keep:

 •       records of analyses for at least 10 years. Data may be kept as laboratory reports, or can be
        transferred to tabular summaries including the date, place, and time of sampling; the name of the
        person who collected the sample; identification of the sample as a routine distribution system
        sample, check sample, raw or process water sample, or other special purpose sample; date of
        analysis; laboratory and person responsible for performing analysis; the analytical
        technology/method used; and the results of the analysis.

        records of action taken by the system to correct violations of NPDWRs for at least 3 years after
        the last action taken with respect to the particular violation involved.
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December 8, 2000

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        records concerning a variance or exemption granted to the system for at least 5 years following
        the expiration of such variance or exemption.

Other required records include State determinations of a system's vulnerability to contamination from
photon and beta emitters, records of current monitoring requirements, and records of the most recent
monitoring frequency decision pertaining to each contaminant.

States exercising primary enforcement responsibility must keep all records of current monitoring
requirements and the most recent monitoring frequency decisions pertaining to each contaplinant,
including the monitoring results and other data supporting the decision, and the.State'sl8ridings based on
the supporting data and any additional bases for such decision. These records;BMisl4ie kept in perpetuity
or until a more recent monitoring frequency decision has been issued.    -  *      &
I-C.3    Reporting
                                                                           •4
                                                                           -artto the State within 48 hours the failure
to comply with any NPDWRs (including faiUfce to comply 'iiiitei:llii^i|i(iilMig requirements).

The laboratory or system must report the.,analytical itsult, inclunfingihe standard deviation, to the State.
However, the State should only repoilldpL violations to the EPA based on the analytical result. The
analytical result is the value that thelaboratory reports, not including (i.e. not adding or subtracting) the
standard deviation. For example, if a laboratocyjRsport indicates that the gross alpha measurement for a
sampling point is 18 ± 2 pCiflL, ften compliaiic^ltthiced monitoring and reporting would be calculated
using a value of 18 pCi/L?(4e C&%141.26(cX3)%
Systems must|Htmde:public notieein;«ertaiii circumstances. After providing notice to consumers, the
water system must send fee;primacy^giBBcy^ copy of each type of public notice (e.g., newspaper, radio,
mail notices, .etesJf'^cigjiSl** letter certifying that the system has met all of the public notification
requirements.'The syst^p^austisend this information to the State within 10 days of completion of each
public notice.          *'";'•     ^

The revised Public Notification (PN) Rule (40 CFR Part 141, Subpart Q) divides the public notice
requirements into 3 tiers based on the seriousness of the violation or situation.  "Tier 1" applies to
violations and situations with significant potential to have serious adverse effects on human health as a
result of short-term exposure. Notice is required within 24 hours of a Tier 1 violation. "Tier 2" applies
to other violations and situations with potential to have serious adverse effects on human health. Notice
is required within 30 days of a Tier 2 violation.  Primacy agencies may grant extensions of up to 3
months •from the time of the Tier 2 violation under certain conditions. "Tier 3" applies to all other
violations and situations requiring a public notice not included in Tier 1 and Tier 2. Notices for Tier 3
violations can be combined into one annual notice, including the Consumer Confidence Report (CCR), if
timing and delivery requirements can be met.
December 8, 2000                               I-10                          Radionuclides Guidance

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The Radionuclides Rule requires CWSs to provide a Tier 2 public notice for regulated radionuclides for
MCL violations and to provide a Tier 3 public notice for violations of the monitoring and testing
procedure requirements. (40 CFR Part 141, Subpart Q, Appendix A). For Direct Implementation
programs, the revised PN Rule went into effect October 31, 2000. Primacy States may set a new
compliance date that shall be no later than May 6, 2002.

All CWSs must deliver a CCR to their customers by July 1 of each year (40 CFR §141.152.(a)). Systems
must include, among other things, water quality data, monitoring results and an explanation of their
significance, and health effects language and "likely source" information for MCL and treatment
technique violations. The Radionuclides Rule updates the specific health effects language jind likely
source information for uranium. (40 CFR Part 141, Subpart Q, Appendix B). The heaJjfi'effects language
for radionuclides is shown in Table 1-4.                                 '-
                                    Ication
   Table 1-4: Standard Health Effects Language for OCR an
Contaminant
Beta/photon emitters
Alpha Emitters
Combined Radium-
226/228
Uranium
Standard Health Effects Language for^GCR and Pu^illJil^ication

Certain minerals are radioactive.andipf^emit forms of radiation known
as photons and beta radiation. Some pifflple who drink water containing
beta and photon emitters in excess of^tbeHMCLover many years may have
an increased risk of getting cancer. \ , V-
Certain minerals are radioactive and may emttafbrm of radiation known
as alpha radiation. Some people who drink water containing alpha emitters
in excess of the MCL over many yearsanay have an increased risk of
getting cancer.
Some people who drink water containing radium 226 or 228 in excess of
the MCL over many years may have an increased risk of getting cancer.
Somerjpeople who drink water containing uranium in excess of the MCL
over many years may have an increased risk of getting cancer and kidney
toxicity.
I-C.4    Moiutoiingipr Gross Alpha, Radium-226, Radium-228, and Uranium
This section presents the IditiaL, reduced, and increased monitoring requirements for gross alpha, radium-
226, radium-228, and urariiaph. Tip use of grandfathered data to satisfy the initial monitoring
requirements is described in the -Section I-C.6.
    *

Also included in this section are tables which summarize the monitoring framework for radionuclides,
figures which schematically illustrate initial and reduced monitoring scenarios, and examples that help
explain the initial and reduced monitoring requirements. While the figures and the examples help to
illustrate many of the potential scenarios, States may encounter many additional situations because of the
unique characteristics of individual systems. The figures are only a guide to help determine monitoring
frequencies for some systems.

l-C.4.0.  Radium-224

Recent studies have shown that there is a positive correlation (1:1) between radium-228 and radium-224.
Since systems with high radium-224 levels will likely also have high radium-228 levels, EPA expects
Radionuclides Guidance
1-11
December 8, 2000

-------
 that the enforcement of a combined radium-226/228 MCL will mitigate the effects of high radiuin-224
 levels.  Although monitoring for radium-224 is not a requirement in this rule, a State, at its own
 discretion, may require water systems to analyze for radium-224.

 I-C,4.b   Initial Monitoring for Gross Alpha, Radium-226/228, and Uranium

 Systems are required to conduct initial monitoring by December 31, 2007 for gross alpha, radium-226,
 radium-228, and uranium (40 CFR § 141.26). Systems can substitute the gross alpha particle activity
 measurement for the required radium-226 measurement if the gross alpha particle activity does not
 exceed 5 pCi/L. Systems can also substitute the gross alpha particle activity measureme^ijlbr the
 required uranium measurement if the gross alpha particle activity does not exceed IS.pteS/L. Ideally, a
 system would establish initial compliance by collecting 4 consecutive quarteiiy-saaiples at each entry
 point to the distribution system (EPTDS) during the initial roun^^imonttanB^j;;?;^^ annual average of
 the quarterly results would determine whether a system is eligibil!%r reducedffionftOfing (See Section I-
 C,4.c below). Figure 1-2 and the results from the initial sampling can be u$gd to e&aBJfciiits reduced
 monitoring frequency.                                  ,           ip
I-C.4.C  Reduced Monitoring for Gross Alpha, Combine,
Standard trigger levels are used to guide the determination of a
the method detection level, Vi the MCL, and the MCL. If a system's.
                                                             ,.w '26/228, and UranWe^f

                                                              •  'S*i. -r ?t
                                                                      iced monitoring frequency:
                                                                       ;rage from the initial four
quarters of monitoring for gross alpha, uranium, combin(rfTadium-22o1^li^^iitew the detection limit,
the system would be allowed to reduce monitoring to ooessainple every nihe'years. (40 CFR
§141.26(aX3)(i))- If a system's annual average.^;g«^||ip^jlB|nium afitf combined radium-2267228
is at or above the detection limit but at or below % the MCt,:ffiiM|steiaa:COuId reduce monitoring to one
sample every six years. (40 CFR §141.26(a)(3)(ii))-  If* systetn^inBJHiaT average for gross alpha,
uranium and combined radium-226/22Sy| above V4 tile MCL bulphof below the MCL, the system could
reduce monitoring to one sample eveqitithree years. (40 CFR §l4l.26(a)(3)(iii)).
Systems on a reduced monitoring schedule    £
must immediately revert back to quarterly     ;
sampling if asample resuJt exceeds the MCL.
(40 CFR$14ifpaX3)(v)).; T*e)f^eni is
eligible for redoced monitoring onfyii|die
average of the initial monitoring readfff|ie
below the MCL or grawlfetfaered datai|pports
the reduction. The State can-also specify a
different schedule as part ofa formal
enforcement action, varianoei or^exemption.
   i
l-CA.d  Increased Monitoring for Gross
         Alpha, Radium-226/228, and
          Uranium

Systems on a reduced monitoring schedule (i.e.,
collecting one sample every 3, 6, or 9 years)
may remain on that reduced schedule as long as
                                                 vff
                                               W         ILLUSTRATION 1-1 ,
                                                Gross Alpha - 7 pGi/L (initial monitoring result)
                                               Gross Alpha = 8 pCi/L (reduced monitoring result)

                                               A system collects 4 quarterly samples for igross alpha
                                               during the initial monitoring period. The annual
                                               average is 7pCi/L (above the detection limit but less
                                               than Vs the MCL).  The system may reduce sampling to
                                               1 sample every 6 years for gross alpha (1 sample
                                               between 2008 - 2013). The system collects its 6 year
                                               sample and the results show an increase in the gross
                                               alpha concentration to 8 pCi/L. The system is required
                                               to increase the monitoring frequency to once every 3
                                               years (1 sample between 2014 - 2016) because the
                                               result was above '/z the MCL but at or below the MCL.
       2States may waive the final two quarters of initial monitoring if the results of the first two quarters are
below the detection limit. The system is then required, under the reduced monitoring requirements, to sample once
every nine years. (40 CFR §141.26(a)(2Xiu)).
December 8, 2000
                                              1-12
Radionuclides Guidance

-------
the most recent sample results support that monitoring schedule. An increase in a contaminant
concentration may increase the monitoring frequency for that contaminant. See Illustration 1 -1.

Any system that has an entry point monitoring result above the MCL while on reduced monitoring, must
increase the frequency of monitoring at each entry point to quarterly sampling. Quarterly sampling must
continue until 4 consecutive quarterly samples are below the MCL (40 CFR § 141.26(a)(3)(v)).

I-C.4.e   Use of Gross Alpha Measurements for Radium-226 and Uranium

The standard monitoring framework for radionuclides is complex, in part, because of the Jnter-
relationship of the analytes (i.e., the alpha
emitters, radium-226, and uranium contribute to
gross alpha activity). Due to this relationship,
gross alpha particle activity analytical results can
be used to determine the reduced monitoring
frequency for gross alpha, radium-226, and
uranium.  Systems that only submit gross alpha
particle activity analytical results and do not
sample for radium-226 may be required,  under the
reduced monitoring requirements, to sample once
every three or six  years rather than once every nine
years.  This is due to the fact that the detection
limit for gross alpha will not allow you to confirm
that radium-226 is below the respective detection
limits as measured individually. See
Illustration 1-2.
                          that i
                    ion limit for j
                   future monitoriag^SlplSey if the:
                       ss alpha particle activity
                       t-226 (40 CFR § 141,26(a)(7)).
                          than the regulatory
                             (1 pCi/L) the system
                             to the reduced
                           « every nine years.
Systems that do not have previous radionuclide
sampling data should sample for gross^pha,
radium-226, and radium-228.  Data collected
during the first quarter may serve as a baseline
indicator of what will need to be collected in the
following quartets. These systems will then
collect subsequent quarterly samples concurrently
with all other quarterly sampling events to
determine compliance with the MCLs. See
Illustration 1-3.3"       fiF    x
         ,*    ILLUSTRATION 1-3
      Systems With No Previous Sampling Results
   **!$£:
   <.ffiy.',*s^
   jppsystem without any previous sampling results
   collects gross alpha, radium-226, and radiumr228
   samples during the first quarter of the initial
   monitoring period. All samples are less than the
   regulatory detection limit The system will likely be
   able to use 14 the gross alpha detection limit to
   determine the value of radium-226 and uranium and
   avoid the cost of collecting quarterly samples for these
   radionuclides. Thus the system would continue to
   collects additional quarterly samples for gross alpha
   and radium-228. The State may allow the system to
   reduce the monitoring frequency for radium-226  and
   radium-228 to one sample every 6 years and one
   sample every 9 years for uranium and gross alpha.
        3For additional illustrations and examples please see Appendix D: SDWIS-FED DTP Reporting
Requirements Guidance.
Radionuclides Guidance
1-13
December 8, 2000

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Systems with gross alpha activity greater than 15
pCi/L are required to monitor for uranium. (40
CFR  141.26(a)(5).  Uranium analysis will serve a
dual purpose for systems with high levels of gross
alpha activity. First, systems can subtract the
uranium activity from gross aipha to determine
compliance with the gross alpha MCL; and
second, the results can be used to determine the
future monitoring frequency for uranium.  See
Illustration 1-4.
      Systems with Gross Alpba Activity >15 pCi/L

   A system ;has data from a previous compliance period
   showing a gross alpha level of 20 pCi/L (above the
   MCL for gross alpha.) The system collects uranium
   monitoring sampfes to subtract me Cranium :activity
   from the gross alpha measurement to determine actual
   compliance with the gross alpha MGL. The:system
   speciates for uranium and determineyjpt the mass to
   activity ratio is 1:1. (Le. W$§fL *$§& pCi/L). The
   system subtracts me ura^^^o^^tration from the:
   igross alph^^whic^^^^gompliance with me -
   gross ali^plt and a&utoring freque
   of 1 saJifevery 6 ye
December 8, 2000
1-14
Radiomiclides Guidance

-------
Table 1-5: Monitoring Frequencies for Gross Alpha, Uranium, and Radium-226/228
Initial
40 CFR 141.26(a)(2)
Reduced
40 CFR 141.26(a)(3)
GROSS ALPHA AND URANIUM
Four consecutive quarters of monitoring at each entry
point.*
Systems may composite up to four consecutive
quarterly samples from a single entry point if analysis
is done within a year of the first sample.
COMBINED RAm|$h2
Four consecutive quarters of monitoring at eachsntry
point.
Systems may composite up to four consecutive
quarterly samples from a single entry point if analysis
is^Sone within a year of theiirst sample.
One
sample
every:
[f theiesul
Y* the MCI
schedule,
Nine years if the average of the initial
monitoring for each contaminant is below
the detection limit listed irt40 CFR
141.25(c) ^jfe'
Six years ifitt»" .f , '^S^KSlia^"'^^^

monitoring results for eaeb'COiitaminaiit is
abegfeyj the MCL but at or below the

, reduce*m acoofdance with the above

26lfl§g|yjM-2^
One
sample
every:
' f i
rtioftiyipars if the average of the initial
monitoring for combined radium-226/228
is below the detection limit listed in 40
CFRI41.25(c).
Six years if the average of the combined
initial monitoring results for combined
radium-226/228 is at or above the
detection limit but at or below Vi the MCL.
Three years if the average of the initial
monitoring results for combined radium-
226/228 is above Y2 the MCL but at or
below the MCL.
if the results from the composited sample is less than
Yi the MCL reduce in accordance with the above
schedule.
* Systems may substitute the gross alpha results that are less than or equal to 15 pCi/L for uranium to determine
compliance and the reduced monitoring frequency. Systems with a gross alpha result greater than 15 pCi/L must
collect uranium sample(s) to determine compliance and reduced monitoring. 40 CFR 141.26(a)(5).
Radionuclides Guidance
1-15
December 8, 2000

-------
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I-C.5   Monitoring for Beta Particle and Photon Radioactivity

This section presents the initial, reduced, and increased monitoring requirements for the beta particle and
photon radioactivity. Figure 1-3 is a flowchart summarizing the beta particle and photon radioactivity
monitoring requirements.

Under the existing rule, States had to evaluate a system's vulnerability to beta emitting sources. States
should use these existing vulnerability assessments to notify systems of their status and of the monitoring
requirements, if they have not provided that notification previously.  The EPA is also encouraging States
to re-evaluate a system's vulnerability to beta particle and photon radioactivity sources ^en conducting
a system's source water assessment and provide immediate notification to thole,systeinMhat have been
deemed vulnerable.                                                    :&':•  ~'•''.

I-C.5. a  Routine Monitoring for Beta Particle and Photon Radioactivity

Under the Final Radionuclides Rule, systems must monitor for beta particle and phi
under the following circumstances:

•       If the system is designated by the State as vulnerable;

•       If the systems is designated by the State as utilizing waters cigi^tij^^d by effluents from
        nuclear facilities; or,                        ....:/:         ^; :t||lip
                                                   .. ".  ,             *J"v '•'.
        The State, at its own discretion, requires?flie-sy?teai%cciilkct samples (40 CFR § 141.26(b)).
                                           -;'"        • "' '' • •*' '    *
Vulnerable systems must collect quarterly simples forieta emittejpiBti'anniial samples for tritium and
strontium-90 at each entry point to the distribution system (40 d3R^i41.26(b)(l)). Sampling must begin
one quarter after being notified by th#$tate. (See Figure 1-3)

Systems designated by the State as utilizing witters contaminated by effluents from nuclear facilities must
also collect quarterly samples for J»eta emittetsand iodine- 131, and annual samples for tritium and
strontium-90*t*ach entrx.fjbifltt^e distribS^|:Sy8tem (40 CFR § 141.26(b)(2)). More frequent
monitoring isrbftlired if iodine- Il|fi|found in finished water (40 CFR §  141 .26(b)(2)(ii)). Sampling
must begin ooe^foarter after beingJBGiiiied by the State. (See Figure 1-3 )
             ^  ••"-''"              ^~, '
l-CS.b  Reduc&Mmutmingfor Eet^f article and Photon Radioactivity
            •   :     ••'  'if
A State may allow a systenijto fedoce the frequency of monitoring to once every three years if:

•   m  In a vulnerable systenVthe gross beta particle activity minus the naturally occurring potassium-
        40 beta particle activity has a running annual average (computed quarterly) less than or equal to
        50 pCi/L (40 CFR § 14 1 .26(b)( 1 )(i)).

•   4   In a system designated by the State as utilizing waters contaminated by effluents from nuclear
        facilities, the gross beta particle activity minus the naturally occurring potassium-40 beta particle
        activity has a running annual average (computed quarterly) less than or equal to the 1 5pCi/L (40
        CFR§141.26(b)(2)(iv)).
December 8,2000                               1-20                         Radionuclides Guidance

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I-C. 5. c   Increased Monitoring for Beta Particle and Photon Radioactivity
A system that exceeds the gross beta particle activity minus the naturally occuring potassium-40 beta
particle screening level (50 pCi/L for vulnerable systems or 15 pCi/L for systems utilizing waters
contaminated by effluents from nuclear facilities), must further analyze the sample for the major
radioactive constituents4 (40 CFR §  141.26(b)(5)). The system must determine compliance with the
MCLs for beta particle and photon radioactivity by using the calculation described in 40 CFR §
141.66(d)(2).

If the results show an MCL violation for any of the constituents, the system must conductimonthly
monitoring at any sampling point that exceeds the MCL. A system can resume-quarterly monitoring if
the rolling average of three months of samples is at or below the MCL (40 GEK§ 44J26(b)(6)).
          Use of Environmental Surveillance Data for Beta Particle and jP/
          Measurements
                                         \activity
I-C.5.d
 States that allow systems to use environmental surveillance data collected by a nuclearlapGity-iMieu of
 the water system's required beta particle and photon radioacttS^yimjijjoitoring should revie^-the data to
 determine if it is applicable to the water system. If the surveillanceaBiiliWndicates that there has been a
 release, systems must initiate collection of quarterly sampling for bddrf&rticle and photon radioactivity
 (40 CFR §§ 141.26(b)(l)(ii) and 141.26(b)(2)(v)).'
    Table 1-6: Monitoring Frequencies for Beta Particle and Photon Radioactivity
                      Initial
                            Reduced
                        BETA P
ANDjpOTON RADIOACTIVITY
  Vulnerable CWSs (as designated by l$e$tate):
  Quarterly samples for beta emitters and annual   :t
  samples for tritium and strontium-Wit each entry
  point, within one quarter after bemgjttptified by the
  State. Already designated systems nHGtcontinue to
  sample in accordance with the compliance schedule
  (40 CFR §141.26$)^,  ,      W
         One sample every three years if the gross beta particle
         ictivity minus the naturally occurring potassium-40
         >eta particle activity has a running annual average less
         han or equal to the screening level (50 pCi/L) (40
         CFR§141.26(b)(l)(i)).
  CWSs utilizing waters contaminated by effluents from
  nuclear facilities (as designated by the State):
  Quarterly samples for beta emitters and iodine-131 and
  annual samples for tritium and strontium-90 at each
  entry point, within one quarter of being notified by the
  State. Already designated systems must continue to
  sample in accordance with the compliance schedule
  (40 CFR § 141.26(bX2)).
         One sample every three years if the gross beta particle
         activity minus the naturally occurring potassium-40
         >eta particle activity has a running annual average less
         than or equal to the screening level (15 pCi/L) (40
          FR§141.26(b)(2)(iv)).
        4A State may require a system to speciate the sample for the most likely emitters associated with the nearby
source.
Radionuclides Guidance
      1-21
                                                                                  December 8, 2000

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                                                          ILLUSTRATION 1-5
                                                Use of Grandfathered Data to Satisfy the Initial
                                                         Monitoring'Requirements

                                            A system with 1 EPTDS has collected gross alpha samples
                                            for the two previous compliance periods under me existing
                                            Radionuclides Rule (1992-1996,1996-2000U The State
                                            tells the system that if they collect EPTDS s&gpes for
                                            gross alpha, radium-226, radhi;
                                            June 2000 and December 7,2'
                                            data and will notjAibject
                                            monitoring r&
                                            effect. Thes;
                                            finds concent
                                            Radium-22
                                            uranium.
                                    ium between
                                 grandfather this
                                     ly       •=':
                                   loesinto     4
                                     ',002 and
                                                                     a compliance schedule of:
I-C.6   Grandfathered Data

The revised Radionuclides Rule balances
the need to ensure that the concentrations
of the regulated radionuclides are at or
below the MCL at every entry point, with
the recognition that some systems have
been monitoring for certain radionuclides
for almost 25 years.  The rule also provides
States the flexibility to decide, based on its
own circumstances, whether to use
grandfathered data. A State must provide,
as part of its Primacy Application, a
description of the procedures and criteria
that it will use to determine the
acceptability of grandfathered data. (40
CFR§ 142.16(1)(1)).

Systems are prohibited from using
grandfathered data to satisfy the monitoring
requirements for beta particle and photon
radioactivity. This prohibition was
established in the 1976 Radionuclides Rule
and the revised Radionuclides Rules does
not deviate from this standard (40 CFR
§l4l.26(b)).                             ;:

States may allow systems to use
grandfathered data to comply with the
initial monitoring requirements forgross
alpha, radium-226/228, and uranium under
some circumstances, inducting tn<|.,:
following. (^|Hustration1-5).M:.

•       Systems with one entry point to the ipstribution system (EPTDS) that collect monitoring data
        between June 2000 and December 7, 2003;

        Systems with multiple EP'TPS that have collected samples for each entry point between June
        2000 and December 7,2$D3; or,
    r
•       Systems with data collected from a representative point in the distribution system between June
        2000 and December 7, 2003. The State must make a written finding that the data is representative
    ;    of each entry point based on the variability of historical contaminant monitoring results and other
        factors listed in the special primacy section of the State Primacy Program application. (40 CFR
        §141.26(aX2Xii)).

I-C.7    Monitoring Waivers

A State cannot allow a system to forego initial or reduced monitoring (40 CFR § 141.26).  In some
circumstances, a State may waive the final two quarters of initial monitoring for a sampling point if the
results of the samples from the two previous quarters are  below the detection limit.
     ts when
   collects
onsof:5ojiCforg
LOL foiJldium-228,
                                                                            alpha since the result
                                                                            fel but less than Vi
                                                                     foi combined radium-226/228
                                                                     It (2piC/L + 3piC/L,) is
                                                                  [CL but less than or equal to the
                                                         bvery nine years for uranium since; the
                                                          ; less than the regulatory detection limit
Radionuclides Guidance
1-23
                                                                                December 8, 2000

-------
 I-C.8     Requirements for New Systems/Sources
New CWSs and systems that begin using a new source
of supply must conduct initial monitoring for gross
alpha, radium-226/228, and uranium (systems only
have to collect sample(s) for uranium if the gross
alpha is greater than 15 pCi/L). This monitoring must
begin within the first quarter after initiating use of the
new source (40 CFR §141.26(a)(l)(ii)). New systems
or systems using a new source of supply may also
have to sample for beta particle and photon
radioactivity if required by the State. Figure 1-2 is a
flowchart that summarizes the monitoring
requirements for new systems/sources.

States may require that new PWSs. systems that bring
on new water sources, or systems that have no prior
history of radionuclide monitoring, to develop an
occurrence profile (i.e. collect 1 sample of gross
alpha, radium-226, and radium-228) to determine if it
is necessary to monitor for uranium. States can also
use the profile to determine which radionuclides the
system must monitor for during the initial monitoring \
period. All new systems must collect samples iaiaccorHaace"
Section I.C.4 of this document. (See Illustration I-65).

I-C.9.    Laboratory Methods  ;
                                                              ILLUSTRATION 1-6
                                                              New System Monitoring

                                                    A water system that commences operation in
                                                    2004 collects its first quarterly sample for gross
                                                    alpha, radiuim226, and radium-228. Hie results
                                                    for all the contaminants are lessjft the
                                                    regulatory detectionJhnit TTjjMystem decides
                                                    to collect oary radyg^gg^pBgross alpha in the
                                                                           and substitute the
                                                                                and uranium.
                                                                                   are all
                                                                    limit
                                                                 e State       ^^^
                                                                 itoring frequen
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        "EML Procedures Manual," 27th Edition, Volume 1, 1990. Available at Environmental Measurements
        Laboratory, U.S. Department of Energy, 376 Hudson Street, New York, NY 10014-3621.
        "Determination of Ra-226 and Ra-228 (Ra-02)," January 1980; Revised June 1982. Available at
        Radiological Sciences Institute Center for Laboratories and Research, New York State Department of
        Health, Empire State Plaza, Albany, NY 12201.
        "Determination of Radium-228 in Drinking Water," August 1980. Available at State of New Jersey,
        Department of Environmental Protection, Division of Environmental Quality, Bureau of Radiation and
        Inorganic Analytical Services, 9 Ewing Street, Trenton, NJ 08625.
        Natural uranium and thorium-230 are approved as gross alpha-particle activity calibration standards for the
        gross alpha co-precipitation and evaporation methods; americium-241 is approved for use with the gross
        alpha co-precipitation methods.                                                , '  ;>
        If uranium (U) is determined by mass-type methods (i.e., fluorometric or lasot^hosplxjirfihetry), a 0.67
        pCi/ng uranium conversion factor must be used. This conversion factor is conservative and is based on the
        1:1 activity ratio of U-234 to U-238 that is characteristic of naturally-occtpli^il^apm in rock-
                                                                              .... J I -f • •
Table 1-8 outlines each method's quality control requirements for sampk handling^jj^sSr^ation, holding
times, and instrumentation as shown in laboratory certificatidii manual ifEPA 815-B-9"wQ


   Table 1-8: Sample Handling, Preservation, HoIdii^piiiaLes and Instrumentation
Parameter
Gross Alpha
Gross Beta
Radium-226
Radium-228
Uranium natural
, - *;
Cesium- 134
Strontium-89 and
-90
»
•Radioactive
Iodine- 131
Tritium 	
Gamma/Photon
Emitters
Preservative '
Concentrated HC1 or
HNO3topH<25
Concentrated HC1 or :;
HNO3topH<2v
Concentrated HC1 or
HNO3 to pH< 2
Concentrated HCI or
HNp,tO;p||*2
Concentrated HCI or
-HNOj to pS'<2-
Gaoocentrated HCI to
p»«2
Concentrated HCI or
HN<33 to pH < 2
None
None
Concentrated HCI or
HNO3 to pH < 2
•'::,
-------
        for a period not to exceed 5 days. A minimum of 16 hours must elapse between acidification and start of
        analysis.
2       P = Plastic, hard or soft; G = Glass, hard or soft.
3       Holding time is defined as the period from time of sampling to time of analysis. In all cases, samples
        should be analyzed as soon after collection as possible. If a composite sample is prepared, a holding time
        cannot exceed 12 months.
4       A = Low background proportional system; B = Alpha and beta scintillation system; C = Gamma
        spectrometer [Ge(Hp) or Ge (Li)]; D = Scintillation cell system; E = Liquid scintillation system; F =
        Fluorometer; G = Low background alpha and beta counting system other than gas-flow proportional; O =
        Other approved methods (e.g., laser phosphorimetry and alpha spectrometry for uranium).
5       If HC1 is used to acidify samples which are to be analyzed for gross alpha or gross beta jgjpvlties, the acid
        salts must be converted to nitrate salts before transfer of the samples to plandiets.    .- ?''•'''


I-C.9.b  Updates Regarding Analytical Techniques

In the 1997 radionuclides methods final rule (62 FR 10168)^Jhe Agency^fpprovec
gross alpha, gross beta, uranium, and the radium-226 and 2tjpjotopes^rhe March 5?
Register also approved suitable calibration standards for theaindjissistSf gross alpha-emit)(ilg§»rticles
and gross beta-emitting particles.                          '.;,  ;:^j|||,r.v

In the 1991 proposed rule (56 FR 33050), the gross beta meti&d cdillM|^been used to screen for the
presence of radium-228 at the proposed MCL of 20 pCi/L for radium^^SJ^j^peyer, with the combined
radium-226 and 228 MCL at 5 pCi/L, the Agency can-;llot^pBmmend tfic^a^^lfie gross beta-particle
activity method for screening of radium-228. Instelad^asiJOiiS&ianalysis fbftiidiurn-228 will be
necessary.                                  •         • •. "*   -, -/-.^  ,

As stated in the April 21, 2000, Radionucjlfcs NODA (65 FR 2457$ffadium-224, a short-lived alpha
emitter, has recently been found in drinking water sipplies. Thft Agency strongly recommends that
States and utilities perform  an alpha.«Balysis within 48 to 72 hours after sample collection to capture the
contribution of the alpha particles train 'the dea^|0f the radwBn-224 isotope.  Appendix IV of the NODA
presents several recommendationsffor determo^^ltbe^pnsence of the short-lived, alpha-emitting radium-
224 isotopemdrinking wattfr.  •-- •         ;     •

I-C.9.C  E&ernatization oftftei^Sumance Evaluation Program

On July 18, 1996'(€|;|p.37464), EPAlfioposed options for the externalization of the Performance
Evaluation (PE) studiesf^o yam (now referred to as the Proficiency Testing or PT program). After
evaluating public commen^ in UieJune 12, 1997 final notice EPA (62 FR32112):
        "...decided on aprQgrojn where EPA would issue standards for the operation of the program,
   »    the National Institute of Standards and Technology (NIST) would develop standards for private
        sector PE (PT) suppliers and would evaluate and accredit PE suppliers, and the private sector
 ;;;;;;:,   woulddevelofKOnd manufacture PE (PT) materials and conduct PE (PT) studies. In addition,  as
 •--.•    part ofthepfc&gram, the PE (PT) providers would report the results of the studies to the study
       participants and to those organizations that have responsibility for administering programs
   ,:     supported by the studies. "

In the April 21, 2000, NODA, EPA stated that the externalization of the PT program could effect
laboratory capacity and the costs of analyses. The PT externalization may also impact the
implementation of the Radionuclides Rule by causing a short-term disruption in laboratory accreditation
and impacting the capacity and workloads of laboratories. EPA solicited comments on how to alleviate
these effects.


December 8,2000                                1-28                         Radionudides Guidance

-------
 To alleviate concerns about the costs of PT samples. States have the option of approving their own PT
 sample providers that can be used instead of the independent third party provider who will be accredited
 by NIST, EPA anticipates that radionuclide PT samples will be available in time to allow for laboratory
 certification before compliance monitoring is required.

 To alleviate concerns about potential laboratory capacity problems, EPA extended the initial monitoring
 period from three to four years so that it would end on December 31, 2007. Also, EPA is allowing
 systems to grandfather and composite data under certain circumstances. In addition, EPA is not requiring
 NTNCWSs to monitor for radionuclides and is not requiring a 48 to 72 hour turn around time for gross
 alpha particle activity.                                                           4;-i?
I-C.9.d  The Detection Limits as the Required Measures of Sensitivity
                                                         •' • • •' >
In 1976, the National Primary Drinking Water Regulations defined 'the
concentration which can be counted with a precision of plus or minus 100
                                                                                >L) as "the
                                                                                    rcent
                                                                                      ¥?imit
confidence level (1.96 a, where a is the standard deviation Qlf|he net coORting rate
CFR 141.25(c)). In the 1991 proposal (56 FR 33096), EPA||^Qsed^ing the met,
(MDL) and the practical quantitation level (PQL) as measures-iiJ^^iformance for specific—
radioanalytical methods. Acceptance limits based on the PQI^^nm^.derived from performance
 evaluation studies were also proposed in the 1991 rule. Sor
                                                                  s found the use of acceptance
                                                                    '"' :\ .
 limits confusing and the relationship to the actual method performanciBiwaB;iiot.clear. EPA has decided
 not to use the proposed acceptance limits, PQL, or MDL but will insteadmamtahi;the DLs from the 1976
 rule.  Table 1-9 cites the DLs or the required sensitivity forIfeeiSpecific ralMSxiiialyses that were listed in
 the 1976 rule and are also cited in 40 CFR 141.25.
Radionuclides Guidance
                                             1-29
                                                                               December 8, 2000

-------
  Table 1-9: Required Regulatory Detection Limits for the Various Radiochemical
                             Contaminants (40 CFR 141.25)
Contaminant
Gross Alpha
Gross Beta
Radium-226
Radium-228
Cesium- 134
Strontium-89
Strontium-90
Iodine- 131
Tritium
Other Radionuclides
Detection Limit (pCi/L)
3
4
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If
A DL for uranium is not listed in 40 CFR 141.25 aitittioiiiltfiroposed ifiiSfi§l991 proposal. EPA did
                                          ,. .;:,,:: *' ^ jj*v* '.&'.*• •£&•!£(& *K}J*. *       ^.->v      «  *
propose a PQL and an acceptance limit but in otter to be caOpstofflLwith ofKer regulated radionuclides, is
not adopting the PQL. The Agency will propose a dete(^l>^iianium in future rulemaking and
will set the limit before December 7,2003 $te compliance
                                    • .

I-C.10  Treatment Technologws
                               •'*'''•
Under the SDWA, EPA must specify best av;
                                                   isgies (BATs) for each MCL. EPA must also
make small System technology assessments ir^eg&laiions that establish an MCL or treatment technique6.
This sec|ic»^aaribes theN^ATl^|^mall systwlt^mpliance technologies for the removal of
I-C.10.a
                                  ,
                               *"*••;
EPA evaluated 'Technologies and Costs' for radionuclides in drinking water in 1992 (EPA 1992).  The
evaluations were updated ia»;T«dinologies and Costs (T&C) draft (1999) and a radium compliance cost
stud^:J998). Table I-10 provides a summary of the Best Available Technology (BAT) for complying
  ''*'"'   MCLs for combined radium 226/228, gross alpha, beta particle and photon radioactivity, and
urannum.
       6EPA must make small system compliance and variance technology assessments for systems serving
populations between 25 and 500, 501 and 3,300, and 3,301 and 10,000.
December 8, 2000
                                           1-30
                                                                      Radionuclides Guidance

-------
                 Table 1-10: BATs for Radionuclides in Drinking Water
Contaminant
Combined radium-226 and radium-228
Gross alpha (excluding radon and uranium)
Beta particle and photon radioactivity
Uranium
BAT
Ion Exchange, Lime Softening, Reverse Osmosis
Reverse Osmosis
Ion Exchange and Reverse Osmosis
Ion Exchange, Lime Softening; Reversejpmosis,
Enhanced Coagulation/Filtration*
 * This assumes that a system already has coagulation/filtration in place.

 I-C.10.b  Small Systems Compliance Technologies

 Under the SDWA, compliance technologies may be listed forNPDWRs MCLs i
 In the case of an MCL, "compliance technology" refers to a technology or other meansibli^jfiffordable
 (if applicable) and that achieves compliance. Possible compl^|S^^inologies include packaged or
 modular systems7 and point-of-entry (POE) or point-of-use (P(§!iiKlment units8.
 Small systems compliance technologies for combined radium-226 an
-------
 under the Environmental Technology Verification (ETV) Program to provide treatment system
 purchasers with performance data from independent third parties.

 Tables I- 11 lists the small system compliance technologies for radionuclides and the limitations of their
 use. Table 1-12 presents the technologies that are appropriate for the three size categories designated in
 the SDWA.

 Table 1-11: List of Small Systems Compliance Technologies for Radionuclides and
                                       Limitations of Use
Unit Technologies
1 . Ion Exchange (IE)
2. Point of Use (POU2) IE
3. Reverse Osmosis (RO)
4. POU2 RO

5. Lime Softening
6. Green Sand Filtration
7. Co-precipitation with
Barium Sulfate
8. Electrodialysis/
Electrodialysis-Reversal
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11. .Enhanced .
Coagulation/filtration
Limitations
(see footnotes)
(a)
(b)
(0
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Raw-Wat^r Quality Range &
,-Tt:;fe; ^nsiderations1
'•Sia&ari'ift**^
,-r
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"•^t^j.^- -,*'
Surface waters usually require
pre-filtration
J&k^.
grace waters usually require
11111?
aiPvvaters
.^" '

Ground waters with suitable
water quality
All ground waters

All ground waters


All ground waters; competing
anion concentrations may affect
regeneration frequency
Can treat a wide range of water
qualities
        National Research Council (NRC). Safe Water from Every Tap: Improving Water Service to Small
i        Communities. National Academy Press. Washington, D.C. 1997.
2       A POU, or "pdlnt-of-use" technology is a treatment device installed at a single tap used for the purpose of
        reducing contaminants in drinking water at that one tap. POU devices are typically installed at the kitchen
        tap, See*e April 21,2000 NODA for more details.

Limitations Footnotes: Technologies for Radionuclides
        3       The regeneration solution contains high concentrations of the contaminant ions. Disposal options
               should be carefully considered before choosing this technology.
        b       When POU devices are used for compliance, programs for long-term operation, maintenance, and
               monitoring must be provided by water utility to ensure proper performance.
December 8, 2000
1-32
Radionuclides Guidance

-------
        c       Reject water disposal options should be carefully considered before choosing this technology. See
               other RO limitations described in the SWTR Compliance Technologies Table.
        d       The combination of variable source water quality and the complexity of the water chemistry
               involved may make this technology too complex for small surface water systems.
        c       Removal efficiencies can vary depending on water quality.
        f       This technology may be very limited in application to small systems. Since the process requires
               static mixing, detention basins, and filtration, it is most applicable to systems with sufficiently
               high sulfate levels that already have a suitable filtration treatment train in place
        5       This technology is most applicable to small systems that already have filtration in place.
        h       Handling of chemicals required during regeneration and  pH adjustment may be too difficult for
               small systems without an adequately trained operator.                     /"." >"
        1       Assumes modification to a coagulation/filtration process already in place.
                                                                        w    ^  '
Table I-12 lists the Small Systems Compliance Technologies fortiMkCurren&y*^fl|Bed radionuclides.
Technology numbers refer to the technologies listed in Table I-ll:"               "^

   Table 1-12: Compliance Technologies by Systein Size Category fo
   NPDWRs (Affbrdability Not Considered, Except for .Uranium, Due
                                         Limitations)

Contaminant
Combined radium-226" and
radium-228
Gross alpha particle activity
Beta particle activity and photon
activity
Uranium
\'-"4^ "
25 - 500
1,2,3,4,5,6,7,8,9

3>4
..;Jv" 1,2,3,4
• . ••..,.?:.. •' •
:• . 1,2,4.10,11
': "'.••:-:--.-!."r.s • . ^K^!'', -
•;•> ':;M%|501 - 3,300 .

••li-03$&1,S,9
3,4
1,2,3,4
1,2,3,4,5, 10, 11
3,301 - 10,000
1,2,3,4,5,6,7,8,9

3,4
1,2,3,4
1,2,3,4,5,10,11
 Note: (1) Numbeis Correspond-tothosetechnologies found listed in the table I-ll.
I-C.lO.c  Waste JbeatmetyHandlingiutdDisposal Guidance

EPA has developed guidance for
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 I-C.11
               Variances and Exemptions
Under SDWA § 1 4 1 5(a) if a system cannot comply with an MCL or a treatment technique and EPA has
not listed a compliance technology, the State may issue a variance.  See Section C.lO.b, and Tables 1-1 1
and 1-12 for more details on compliance technologies.  A variance generally allows the system to provide
water above the MCL on the condition that the water quality is still protective of public health. The
system is required to install, operate, and maintain a variance technology that is affordable considering
the size of the system and the quality of the source of supply.

1-C.lLa Small System Variances                                               't

Small system variances9 are not available for any contaminant regulated undw^bej&rdionuclide Rule
because:
                                                                     ^"'"^
       EPA has identified affordable compliance technologies for all of thVconi
       uranium.
I-C.ll.b General System Variances
Under SDWA §1415(a) States may grant a variance to any size sys^jsin^
system cannot meet the MCL requirements of a reguiation'after the
sources of water are not reasonably available. Systeros-irtl^iinstall, o
approved BAT and enter into a compliance schedule.
                                                                     raw water available to the
                                                                        led and alternative
                                                                          aintain a State
                                         x# " »•'       t . ».T^'|i^':« yW' • '
All systems are eligible for general variancessfrom the MCLsloCjgKttijvalpha, combined radium-
2226/228, uranium, and beta particle and photon emitters.  Howewtrasystem must meet the
requirements in §1415(a) of SDWA to qualify for a general variance'
1-C.ll.c Exemptions            .j<"l'

The MCLs for gross alpha, radffltt^226/228,
                                                    tide and photon emitters were promulgated in
1976. The maximum exeiqptioivgferiod is nin&jtevs from the effective date of the MCLs. Therefore, the
exemption pedodhas expired forihiae contaminants. The Agency has promulgated a new MCL for
uranium in the2(KW;JEbdionuclid«5S^feu|te. A State may issue an exemption to a PWS for the uranium
MCL if the system meets the criteria-stated in SDWA §1416.
            •*    •*"   '.'.- <*<' ••'! '         •-. ' -J- !>_*'* ' :          **
       'Systems serving fewer than 3,300 people are eligible for a small system variance. Systems serving
between 3,300 and 10,000 people are also eligible for a small system variance however the EPA Administrator must
approve of the State's variance decision.
December 8, 2000
                                             1-34
Radionuclides Guidance

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Radionuclides Guidance
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December 8, 2000

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Section II.
SDWIS Reporting Violation
             .,'andSNC

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II-A.   SDWIS Reporting
The following table (Table II-1) is a summary of Safe Drinking Water Information System/Federal
(SDWIS/FED) reporting requirements for the Revised Radionuclides Final Rule. The summary contains
SDWIS/FED violation and contaminant codes.

This table only lists potential federal violations. Appendix D provides SDWIS/FED DTP reporting
guidance on how to place these violations in the appropriate structure so that SDWIS/FED can accept
them, when reported.
Table II-l: Revised Radionuclides Final Rule Federal
                                                                          iolations
Contaminant
Code :
4000
4010
4006
4101
4102
4174
4264
4270
4172
Contaminant : M
: •••••'' $\
Gross Alpha
Combined Radium (-226 &-228)
Combined Uranium
Man-Made Beta Particle and Photon Emitters
Tritium ,;>;
Strontium-90 ; i; >i
Iodine-131
Cesium- 134
Strontium-89
^T^^k. J
s •» $3e£--£~'M*&&¥~?F?£ • * ' >'
cn m.~"HA '•-• ~fs^fS-Si~f'--
UZ. \l£i vO ."' ;^i-*^MJi"-
v ' At * •**• >»'**»: .' •
<•-,««' v . - - >•-
1^09.06
«,«w5ss,&,m _ •
02,03,06
O2,"oa^e6j^_ ;>
02,03,0^-^"
5(x V ' - -
fita&j»"'v

02, 03, 06
02, 03, 06
Note: Violation;Types and Definitions
       02-iMqti* Average
           '""""
       06 -
Radionuclides Guidance
                                      11-3
December 8, 2000

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 II-B.   Violation Determination
II-B.l   Violation/Compliance Determination for Gross Alpha, Radium-226/228,
          and Uranium

Compliance will be determined based on a running annual average of quarterly samples collected at each
entry point. If the running annual average at any entry point exceeds an MCL, the CWS would be in
violation (40 CFR § 141.26(c)(3)).  Noncommunity water systems are not subject to the requirements of
the Radionuclides Rule                                                       /&>•
An immediate violation will occur for any individual sample analytical res
analytical results, that would place the system in violation beforeiliiir
                                                       '•"%&*&?&:*
the sample is greater than 4 times the MCL, or the average of Jaiiirst two
the MCL). CWSs that exceed an MCL while on reduced motoring must^Jiisgin
quarter following the one in which the exceedance occurred^|ind compjyjihce will
consecutive quarters of analytical results beginning with th&jnj&al exCeedance. Qu
continued until 4 consecutive quarterly samples do not exceeolB|i^EiL, or until a monit<
as a condition to a variance, exemption, or enforcement actioh^e^p^effective (40 CFR
§141.26(a)(2)).
                                       'ination of sample
                                       are collected (e.g.,
                                          :er than twicer
                                            lonitoringsthe
                                                 ing is
                                             'schedule,
If a system fails to collect all samples required during any^ear, comp
available data (40 CFR §141.26(c)(3)(ii)).  If a systa%Sfc^., of the 4
annual average will be based on the samples
                                    calculated based on
                                   quarterly samples the
II-B.2    Violation/Compliance Defgrminatidn for <
                          (eta and Photon Emitters
The Radionuclides Rule uses a "sum-jSftthe-fractions" method to determine whether a system is in
compliance with the MCL for beta particle and photon radioactivity (40 CFR § 141.66(d)). This method
is used because each photon emittertargets a different organ of the body which results in a different
magnitude o£risk. The sum of thejeta and pljblpteinitters shall not exceed 4 millirems/year (40 CFR
§141.66(4!""" '          " '    *""        """""	'
While the i
  "millirems," contaminants are analyzed in the "pCi/L".
ib«*a and photon emitter must be converted from pCi/L to
  in "Maximum Permissible Body Burdens and Maximum
Therefore, to detenmne^cpniplianceji
millirems using jtfie coavpi ion tables
Permissible ConcentratioiH of Radionuclides in Air or Water for Occupational Exposure" (MBS
Handbook 69 as amendedflfflpis*,; 1963, U.S. Department of Commerce).  See Appendix H for the
conversion tables.        '

Thejcolumn titled, "1976 limits based on critical organ at 4 mrem/yr" indicates what 4 mrem of exposure
wotiki be for that contaminant in pCi/L.  For each emitter that is detected by the laboratory, the system
raysfettivide the pCi/L found in the sample by the value in the conversion tables.  This provides a fraction
of l»eW]iiaudi,the particular beta or photon emitter is providing towards the maximum of 4 mrem/yr for
the all of ^el>eta photon emitters.
        pCi/L found in sample (from laboratory
        results)

        pCi/L equivalent of 4 mrem of exposure
        (from conversion table)
           = fraction of the maximum 4 mrem/year
           exposure limit
December 8, 2000
        11-4
Radionuclides Guidance

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If the sum of the fractions is greater than one, the
system has exceeded the 4 millirem/year MCL
for beta particle and photon radioactivity.  (See
Illustration II-1).
               ILLUSlltATIONltl
        Conversion of Beta Photon Emitters

   A water system near a nuclear power facility collects a
   sample which the laboratory speciates by gamma spec
   analysis. The analysis indicates the following:
           Cesium-134(Cs-I31):
           Iodine-131 (1-131):
                                                                                  4,023 pCi/L
                                                   The sya$Hn is in violation of the MCL because the
                                                          f-the-ftactions" exceeds 1, which indicates that
                                                          of the annual dose equivalent to the total
                                                      ly, or to any internal organ, has exceeded 4
                                                   millireras/year.
Radionuclides Guidance
II-5
December 8, 2000

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II-C.   SNC Definitions

The following SNC definition is applicable to the current radionuclide rule. The definition has been
taken from an EPA Memorandum dated May 22,1990.  The SNC definition is part of a three-tiered
prioritization scheme for all violators of the National Primary Drinking Water Regulations (NPDWRs).
Tier 1 is composed of the SNCs - those violators which present the greatest risk to health and which,
therefore, are generally primary enforcement targets.  Tier 2 represents an intermediate set of violators.
Some of these are in violation of an MCL, but the level of the contaminant is sufficiently low that it does
not pose an immediate threat to public health. Tier 3 contains the rest of the violators of jibe NPDWRs.
A Radiological SNC is a PWS which meets any of the following Tier 1 critetp:
       (a) Exceeds the unreasonable risk to health level ident
               unreasonable health level is 2 times the MCL.

       (b) Fails to monitor for or report the results of any a
               two consecutive compliance periods if they:
               monitor or report results once if they monitoi
               frthat
                     regulated
                 iore than once a
                     or less.
A Tier 2 violator is a PWS which meets any of the following'Crite
                                                                -.--
       (a) All violations of the radiological MCLs where:the concentratwipiflbe contaminant does not
               exceed the unreasonable risk to healtkJeveL             '•
       (b) Any monitoring/reporting violatil
                                                !,:•        , I ;tl::M«~
A Tier 3 Violation is not applicable tq^ftdiologicaljcontaminanti, because all violations of radiological
       MCLs and/or monitoring aridjteporting requirements begin as Tier 2 violations.
December 8, 2000
11-6
Radionuclides Guidance

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Section III
Primacy
Appli

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                             This page has teen
December 8, 2000
111-2
Radionuclides Guidance

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III-A. State Primacy Program Revision

40 CFR §142 sets out requirements for States to obtain and/or retain primary enforcement responsibility
(primacy) for the Public Water System Supervision (PWSS) program as authorized by §1413 of the Safe
Drinking Water Act (SDWA). The 1996 SDWA Amendments update the process for States to obtain
and/or retain primacy. On April 28, 1998, EPA promulgated the Primacy Rule to reflect these statutory
changes (63 FR 23361).

Pursuant to 40 CFR § 142. 12, Revision of State Programs, complete and final requests for^approval of
program revisions to adopt new or revised EPA regulations must be submitted to the Adttnnistrator no
later than 2 years after promulgation of the new or revised federal regulation^ee TaWe III-l). Until
those applications are approved, EPA Regions have responsibility1 for direcl|^if^penting the
Radionuciides Rule. The State and EPA can agree to implement|beTule tog^plp|i|g this period.
EPA anticipates that for the Radionuciides Rule, those responsibilities will M^fvii^^^.treach to
ensure that systems desiring flexibility for initial monitoring are able to :giandfather;i^^giate data.
However, if a State is eligible for interim primacy, once it submits a complete and finil%Sfeisi0n-package,
it will have full implementation and enforcement authority. A State-may be granted an expansion of time,
up to two years, to submit its application package. During any extension period, an extension agreement
outlining the State's and EPA's responsibilities is required.
          Table III-l: State Rule Implementation and Revision^Fimetable for
                                      E         ,-••.-        '••-.'- '-"\. ,_- • •  ;v"
                                    Radionuciides iUtte
EPA/State Action , , '.";.•,;'"".
Rule published by EPA
State and Region establish a process and agree upon a schedule for application
review and approval
State, at its option, submits draft program revision package including:
Prelinuaary Approval Reqwisst
Draft State Regulations ai^orsStatutes
RegiilifiijtoCrosswaik _ /;• '•'-. '
Regional (and Hee^autes if necessary)»eview>of draft
State submits final program revision .package including:
Adopted State Regulations
Regulation Crosswalk
40 CFR 142. 1 0 Primacy Update Checklist
' 40 CFR 142. 14 and 142. 15 Reporting and Recordkeeping
40 CFR 142.16 Special Primacy Requirements
Attorney General's Enforceability Certification
EPA final review and determination:
; Regional review (program and ORC)
Headquarters concurrence and waivers (OGWDW, OECA, OGC)
Public Notice
Opportunity for hearing
EPA's Determination
Rule Effective Date
Time Frame
December 7, 2000
May 2001
September 2001
(Suggested)
Completed within 90 days
of State submittal of Draft
by September 7, 2002*
Completed within 90 days
of State submittal of final
45 days Region
45 days Headquarters
December 7, 2003
* EPA suggests submitting an application by September 2002, to ensure timely approval. EPA regulations allow
until December 7, 2002 for this submittal. An extension of up to 2 additional years may be requested by the State.
Radionuciides Guidance
III-3
December 8. 2000

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 III-A.1  The Revision Process
 The approval of State program revisions is recommended to be a two-step process comprised of
 submission of a draft request (optional) and then submission of a complete and final request for program
 approval.  Figure III-l diagrams these processes and their timing.

 Draft Request — At the State's option, it may submit a draft request for EPA review and tentative
 determination. The request should contain drafts of all required primacy application materials. A draft
 request should be submitted by 9 months after rule promulgation. EPA will make a tentative
 determination on whether the State program meets the applicable requirements. The tegpive
 determination should be made within 90 days.                            , .    .$?
                                                                              §142.12(c)(l)and
                                                                                   to any  .f
                                                                                         Itfor
Complete and Final Request — This submission must be in aefeepdance
(2) and include the Attorney General's statement. The State sttimcf also incj
comments and/or program deficiencies identified in the tentative determin
Regions should make States aware that submission of only i final requ^Pmay
the States to address any necessary changes within the allowdWeamtfJfor State rule
EPA requests that States submit their complete and final revi
promulgation. This will ensure that States will have interirctprim
States from becoming backlogged with revision applications to ado]
The State and Region should agree to a plan and tj
application as soon as possible after rule prom
                                                                  within 21 months of rule
                                                                      months and will prevent
                                                                        ;ral requirements.
                                                          mitting nwSState primacy revision
                                                             in 5 months of promulgation.
                                                         .•;<^:.r-!;s .%»**>
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   Figure III-l: Recommended Review Process for State Request for Approval of
                                   Program Revisions
                                       EPA Promulgates
                                      Radionuclides Rule
                                     Establish Process and
                                  Tentative Schedule for State
                                        Rule Approval
                                      State Submits Draft
                                  Primacy Revision Application
                                           to EPA
                                        §142.12(d)(1)(i)
                                       EPA Review and
                                    Tentative Determination
                                       (within 90 days)
                                       §142.12(d)(1)(ii)
                                        State Submits
                                      Complete and Final
                                 Primacy Revision Application
                                           to EPA
                                        §142.12(d){2)(i)
                                       EPA Review and
                                        Determination
                                       (within 90 days)
                                        §142.12(d)(3)
                            December?. 20CC
                           r 2001
      S Months
                    I -scsrr; jsr 2002
Radionuclides Guidance
III-5
December 8, 2000

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III-A.2  The Final Review Process

Once a State application is complete and final, EPA has a regulatory (and statutory) deadline of 90 days
to review and approve or disapprove of the revised program. The Office of Ground Water and Drinking
Water (OGWDW) will conduct detailed reviews of the first State package from each Region. We ask
that the Region submit their comments with the State's package for Headquarters review. Where the
Region has identified ail significant issues, OGWDW will waive concurrence on all other State programs
in that Region, although they will retain the option to review additional State programs with cause. The
Office of General Counsel (OGC) and the Office of Enforcement and Compliance (OECA) has delegated
its review and approval to the Office of Regional Counsel (ORC).                    '
In order to meet the 90 day deadline for packages undergoing Headq
will be equally split giving both the Regions and Headquarters .^jjl&iys to
reviews. For the first package in each Region, Regions shouldjiSs^rward copii
applications to the Drinking Water Protection Division Director in OGWDW,
the review process.                                   . j-i        '
                                                               '
                               ie review period
                                respective
                                     revision, ;
                                      e lead on
December 8, 2000
III-6
Radionuclides Guidance

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III-B.  State Primacy Program Revision Extensions

III-B.l  The Extension Process

Under § 142.12(b), States may request that the 2-year deadline for submitting the complete and final
request for EPA approval of program revisions be extended for up to 2 additional years in certain
circumstances. The extension request must be submitted to EPA within 2 years of the date that EPA
published the regulation. The Regional Administrator has been delegated authority to approve extension
applications. Headquarters concurrence on extensions is not required.                 i; ,.
III-B.2  Criteria that an Extension Request Must Meet

For an extension to be granted, the State must demonstrate that it3s*requesti
cannot meet the original deadline for reasons beyond its control, despite a good fat
critical part of the extension application is the State's proposed schedulefbr submis
and final request for approval of a revised primacy program. T-JKLapntication must alsdl
least one of the following:
       (0
       (ii)
       (iii)
That the State currently lacks the legislative or
revised requirements; or,
                                                                ion because it
                                                                 etc do so. A
                                                                    complete
                                                                   jnstrateat
authority to enforce the new or
That the State currently lacks the program capability adequate to implement the new or
revised requirements; or,      /    	    ftk;;;;;,       ••-'•
That the State is requestingUie extension to gr
single legislative or regulatory action.
more program revisions in a
In addition, the State must be implementing the EPA requirements to be adopted in its program revision
within the scope of its current authority and capabilities.

III-B.3  Conditions of the Extension

To be granted an extension, the State mast agree to certain conditions that must be met during the
extension period. These conditions will be negotiated by the Region and the State during the extension
approval proces$:andjpeJbdded on a^case-by-case basis. The conditions must be included in an
extension agreementlJiB^pm the State and the EPA Regional office. Appendix B contains a sample
extension agreement   4E   :'.,.•

Coijditions of an extension-agreement may include:

        •      Informing PWSs of the new EPA (and upcoming State) requirements and that the Region
              will be overseeing implementation of the requirements until they approve the State
    -         program revisions or until the State submits a complete and final revision package if the
              State qualifies for interim primacy.

        •      Collecting, storing and managing laboratory results, public notices, and other compliance
              and operation data required by the EPA regulations.

        •      Assisting the Region in the development of the technical aspects of enforcement actions
              and conducting informal follow-up on violations (telephone calls, letters, etc.).
Radionuclides Guidance
                              III-7
            December 8, 2000

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        •       Providing technical assistance to PWSs.


        •       For States whose request for an extension is based on a current lack of program
                capability adequate to implement the new requirements, taking steps agreed to by the
                Region and the State during the extension period to remedy the deficiency.


        •       Providing the Region with all the information required under §142.15 on State reporting.


Table III-2 provides a checklist the Region can use to review State extensions.
                                                          , , -,i !..<-•!#j[sjp&'I', .
                                                                   ••
December 8, 2000
III-8
Radionuclides Guidance

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                           Table III-2: Extension Request Checklist
  I. Reason for State Request
                 	 Clustering of Program Revisions
                 	 Statutory Barrier
                 	 Regulatory Barrier
                 	 Lack of Program Capability
                                 	 Insufficient Resources
                                 	 Funding Level
                                 	 Staffing
                                                                            ," ""' •"<,<> *£•
                                         Lack of Adequately Trained Staff
                                         Inadequate Procedures, Guidelines, and Policies £&&.:••.•••
                         Other
  II. Actions Taken by the State to Justify an Extension
                                                                                       Schedule Dates
                                                                                      (or attachments)
                         Seeking Increases in Program Resources
                         Training Existing Personnel/Revtsmg Ttainfiig Programs1
                         Revising State Regulations or Statutes       .;:~'
                         Developing Revised/New Procedures, Guidelines, Policies
                         Other             	
  IH. Extension Decision
                         ExtensJonltequest Approved
                                                           Date:
                                                                                    to
                                .;;.••• •".,.'  Period of Extension Request:  	/___/_
               	Extension Request Denied            Date:   /    /
                       .   .     _____ Reason Cited:	
IV. Conditions of the Extension  c
   During the extension period the State will (check all that apply):
   T            	 luform public water systems of the new requirements and the fact that EPA will be
                       overseeing their implementation until the State's program is approved or submitted if
                       the State qualifies for interim primacy
               _____ Collect and store laboratory results and other compliance data
    '•'•;;;; :       	 Provide technical assistance to public water systems
               	 Provide EPA with the information required under section 142.15 of the primacy rule
               	 Other	                                     	
Radionuclides Guidance
                                                III-9
December 8, 2000

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III-C.  State Primacy Package

The Primacy Revision Application package should consist of the following sections:

III-C.l  The State Primacy Revision Checklist (40 CFR 142,10)

This section is a checklist of general primacy requirements, taken from 40 CFR 142.10, as shown in
Table III-3. In completing this checklist, the State must identify the program elements that it has revised
in response to new Federal requirements. If an element has been revised the State should^dicate a "Yes'
answer in the second column next to the list of program elements and should submit aj$P6priate
documentation. For elements that need not be revised, the State need only lisiji&£ia»iitbn and date of
adoption in the second column. During the application review process, EP^|if!iiiKrt findings and
comments in the third column.
                     Table III-3: State Primacy Revision Checklist
''>'•%
Required Program Elements /
§142.10
§142.10(a)
§142.10(b)(l)
§142.10(b)(2)
§142.10(b)(3)
§142.10(b)(4)
§142.10(b)(5)
§142.10(b)(6Xi)
§142.10$X6$9t
§142.10(b)(6^H^
§142.10(b)(6)(jyl
§142.10(k#*)(v)
§142,t^b)(6)(vi)
§l4-10(b)(6)(vii)
|H2.iO(c)
§W2U10(d)
; ~V
§,l4Tif9Ce)
§1427^(f)
Primary Enforcement < •
- Definition of Public Water System*
Regulations No Less Stringent
Maintain Inventory ,-•• """ ;
Sanitary Survey Program , .
Laboratory Certification Program /; ;
Laboratory CapabiU|| ,. /-• ^
Plan Review Projsjjfn -^
Authority,*!) ^Djjf regulatiot|si|^ :;- i
Authority to swritt
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The 1996 SDWA Amendments include new provisions for PWS definition and administrative penalty
authority. States must adopt provisions at least as stringent as these new provisions, now codified at CFR
142.2 and 142.10. Failure to revise primacy for these new provisions can affect primacy for the
Radionuclides Ruie. However, States may still receive interim primacy for the Radionuclides Rule even
if they have not yet revised their base program to comply with the new statutory requirements provided
that the State has received an extension to adopt these requirements and that this extension period has not
expired (up to April 2002 with full extension).

Rule Bundling — States may bundle the primacy revision packages for multiple rules so long as the
submittal date (two years plus two year extension) has not lapsed. The Attorney General*Statement
should reference the new requirements.

III-C.2  Text of the State's Regulation                   >

Each primacy application package must include a citation to the applicable State regoldiaii.%40 CFR
§142(cXO(i).                                          ,         •  "'       '--'^Ste;:''

III-C.3  Primacy Revision Crosswalk
                                                          '* •*" -l < ,
The Primacy Revision Crosswalk, found in Appendix C, should be completed by States in order to
identify State statutory or regulatory provisions that correspond to eachiFedfflrail requirement. If the
State's provisions differ from Federal requirements, the State should explainliow its requirements are
"no less stringent."                                    -lj"••;             i"
III-C.4  State Reporting and ReconJkeeping (40 CFX342.14 and 142.15)

There are no new State recordkeeping requirements (40 CFR §142.14) under the Radionuclides Rule.
However, States must continue to comply with existing reporting and recordkeeping requirements that
pertain to Radionuclides.                    v

III-C.5  Special Primacy Requirements (40 CFR 142.16)
Section
III-C.6  Att
;c%-^|||j(DgBr States may choose to meet each special primacy requirement.

rat's Statement of Enforceability
The complete and final priBw^lBWision application must include an Attorney General statement
certifying that the State rejjjiilitoiffsf were duly adopted and are enforceable. The Attorney General
statement should also certify that the State does not have any audit privilege or immunity laws, or if it has
such laws, that these laws do not prevent the State from meeting the requirements of the Safe Drinking
Water Act. If a State has submitted this certification with a previous revision package, then the State
should indicate the date of submittal and the Attorney General need only certify that the status of the
audit laws has not changed since the prior submittal. An example of an Attorney General statement for
the Radionuclides Rule is presented in Table 111-5.

III-C.7      Variances and Exemptions

States wishing to have the ability to grant general variances or exemptions for uranium for this rule must
also adopt 40 CFR §142.65. See Section I-C.11 for more information on variances and exemptions.
Radionuclides Guidance
                  III-11
December 8, 2000

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                    Table III-4: Example of Attorney General Statement
  Model Language

  I hereby certify, pursuant to my authority as d) and in accordance with the Safe Drinking Water Act as amended,
  and (2). that in my opinion the laws of the [State / Commonwealth of {3}] [or tribal ordinances of (4)1 to carry
  out the program set forth in the "Program Description" submitted by the £5) have been duly adopted and are
  enforceable. The specific authorities provided are contained in statutes or regulations that are lawfully adopted at
  the time this Statement is approved and signed, and will be fully effective by the time the program is approved.
 Guidance For States on Audit Privilege and/or Immunity Laws

 In order for EPA to properly evaluate the State's request for approval, the State
 legal counsel should certify that the State's environmental audit immu||jjy,and/o]
 does not affect its ability to meet enforcement and information gathapiijjfrequiremi
 Water Act. This certification should be reasonably consistent wittflfie wording o;
 demonstrate how State program approval criteria are satisfied.
 EPA will apply the criteria outlined in its "Statement of Principle^ ffiemaissued on 2/14/97 (si
 determining whether States with audit laws have retained adequate^aforeanent authority for any authorized
                                   :ral or independent
                                    immunity law
                                      Safe Drinking /
                                         s and should
                                           nix E) in
 federal programs. The principles articulated in the guidance are based'
 specifically the enforcement and compliance and State program ajppro
 and their corresponding regulations. The Principles provide thaHf provisn
 be important to obtain opinions from the State Attorney GeaOBflw indepen
 law as meeting specific federal requirements. If the law
 necessary to obtain federal program approval. BefOTft«irrrtitti|g^ii^ikage for
 privilege and/or immunity laws should initiate con»nunications>w
                    ._       _____  j.-' '•    ._ _    . i.	  ^
                        irements of federal law,
                           of environmental statutes
                               are ambiguous, it will
                                ;el interpreting the
                               to State laws may be
                            al, States with audit
                               ;ional Offices to
 identify and discuss the issues raised by the State's audit privilege^aaaJlDiJinBl8mity law.
 Model Language                       /

 I.       For States with No Audit iWvilege andlar Immunity Laws

 Furthermore, I certify that [Sfate/Ganmonwealifa of (3.1 has not enacted any environmental audit privilege
 and/or imnMfcfcliaws.
                    .,
 II.      For Sti|lf3|ith Audit LawiitattdO Mot Apply to the State Agency Administering the Safe
 Furthermore, I certify thattfeenvironmental [audit privilege and/or immunity law] of the [State / Commonwealth
 of (3)J does not affect (3) abiH^||Oineet enforcement and information gathering requirements under the Safe
 Drinking Water Act becausejtfrelpudit privilege and/or immunity law] does not apply to the program set forth in
 the *'Program Description."-The Safe Drinking Water Act program set forth in the "Program Description" is
 administered by (5); the [audit privilege and/or immunity law] does not affect programs implemented by (5). thus
 deprogram set forth in the "Program Description" is unaffected by the provisions of [State / Commonwealth of
 £2U [audit privilege and/or immunity law].
December 8, 2000
III-12
Radionuclides Guidance

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  III.      For States with Audit Privilege and/or Immunity Laws that Worked with EPA to Satisfy
          Requirements for Federally Authorized, Delegated or Approved Environmental Programs

  Furthermore, I certify that the environmental [audit privilege and/or immunity law] of the [State / Commonwealth
  of (3)1 does not affect (3J. ability to meet enforcement and information gathering requirements under the Safe
  Drinking Water Act because [State / Commonwealth of (3VI has enacted statutory revisions and/or issued a
  clarifying Attorney General's statement to satisfy requirements for federally authorized, delegated or approved
  environmental programs.
  Seal of Office
                          Signature
                         Name and Title
                          Date
                                                                      !'3r5
                                                                             illegal counsel
(1)     State Attorney General or attorney for the primacy agency if it has
(2)     40 CFR 142.1 l(a)(6)(i) for initial primacy applications iWl42.12(c)(l)(ii0ifiSr primacy program
        revision applications..                        - -  •                  -
(3)     Name of State or Commonwealth                  •      "•'••-_,»'
(4)     Name of Tribe                                        / ,r;5if;':
(5)     Name of Primacy Agency                                ...  .
Radionuclides Guidance
                                               III-13
December 8, 2000

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 III-D.  Guidance for Special Primacy Requirements
 This section contains guidance States can use when addressing the special primacy requirements of 40
 CFR 142.16. It specifically addresses the special primacy conditions added for implementation of the
 Radionuclides Rule. The guidance addresses special primacy conditions in the same order that they
 occur in the rule.

 States should note that, in several sections, the guidance makes suggestions and offers alternatives that go
 beyond the minimum requirements indicated by reading the subsections of §142.16.  EPA;-does this to
 provide States with  information and/or suggestions that may be helpful to States' implementation efforts.
 Such suggestions are prefaced by "may" or "should" and are to be consideredOKlviso^r They are not
 required elements of States' applications for program revision.
III-D. 1  Special Primacy Requirements
§142.16 Specialprimacy requirements. (1) An application for•qpproy&bfa State pi
Radionuclides which adopts the requirements specified in 14,
(in addition to the general primacy requirements enumerated^
regulations be at least as stringent as the Federal requiremet

(l)Ifa State chooses to use grandfathered data in the manner descru
State must describe the procedures and criteria whiefcftm>8lme to m,
distribution system or entry point sampling points are*tse$.
(i)
                                                        (ii)(C) must contc
                                                           including that State
              hfor
            following
                                                        Wjjjmi36(a)(2)(ii)(C), then the
                                                          '   "" " 'terminations (whether
               The decision criteria that thState willjUse lO-d^aM^Jhat data collected in the
               distribution system are rejjijresentativeiofthe draU^^/ater supplied from each entry
               point to the distributi& system. These determinations must consider:
               (A) All previous m&jOtoring data.
           ....  (B) ThevariaUonmrepor
           '•"  (C) Other.:^teU»9^ecting th&riftpesentativeness of the data (e.g. geology).
Guidance

The Revised'.
the distribution syster
systems to use monitoring
requj&ments.
                      requiwiiystems to collect compliance samples from each entry point to
                     !)MO CFR § 141.26(a)(2)(ii)(E) gives States the flexibility to allow
                     collected from the distribution system to satisfy the initial monitoring
EPA believes that requestS'for use of grandfathered data are best handled by States on a case-by-case
Basis. Therefore, to meet this special primacy requirement, States' applications for program revision must
demonstrate that eafifa request for use of previously collected data will be evaluated on its merits. The
           nsasf include an explanation of how the State will use all previous monitoring data, and the
variation la reported activity levels. It must also explain what other factors affecting the
representativeness of the data the State will use to determine if the data can be used for the initial
monitoring requirement.
December 8, 2000
                                     III-14
Radionuclides Guidance

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For example, a State may find that the distribution samples are representative of each entry point for a
system that has:

*       Three wells, drawing from the same aquifer, that are from different parts of a well field,

        Three EPTDS, and

        Good historical data showing low to no uniform radionuclide occurrence from the raw water and
        the distribution system samples.
Radionuclides Guidance
III-15
December 8, 2000

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 (2) A monitoring plan by which the State will assure all systems complete the required monitoring within
 the regulatory deadlines. States may update their existing monitoring plan or use the same monitoring
plan submitted for the requirements in §142.16(e)(5) under the National Primary Drinking Water
Regulations for the inorganic and organic contaminants (i.e. the Phase II/V Rules). States may note in
their application any revision to an existing monitoring plan or note that the same monitoring plan will
be used. The State must demonstrate that the monitoring plan is enforceable under State law.
Guidance

For 40 CFR §142.16(1)(2)> States should simply explain how they will modify their mo:
radionuclides to fit within their existing monitoring plan for Phase II/V organjciand i:
contaminants. EPA recommends that States without Phase II/V primacy e
monitoring for all of their systems. Some States may choose to al^Be-in tin
                                                                                  ing plan for
                                                                                  ic
                                                                              edule for initial
                                                                               over the 3 year
compliance period based on system size or source of water. Overstates mayasra^^^uire 1/3 of their
systems to monitor during each year of the 3 year compliance period. "I iilrfl' in iiy j|ifOffljliiJ submttV;stich
a schedule with their primacy revision application. States could also spjefSsjify that thi
schedule they developed for implementing the Phase II/V rft|«i|J|n.dltrdized moniton^^^^^pork) for
inorganic and organic contaminants. The Revised Radionucl|ii^gft|was developed so
radionuclides monitoring would fit into the standardized monil^i^^^|ework. The State must also
describe how the schedule will be enforced and the authorityihat-^w«lWi.the State to enforce the
December 8, 2000
                                             111-16
Radionuclides Guidance

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                   >V^:-r;pS*W
Section IV.
Other Resources and

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                                                                          1



                                                                       •t,  »--•»,» V
                                                                          -* - rgSs-
                                                               a*
                              This page hasJee'n
December 8, 2000
IV-2
Radionuciides Guidance

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 IV-A.  Fact Sheet
         l EftviraramotU Protwbwi Agency
Office of Water
                                                                --  Ground Wbter
                                                                    Drinking Water
                                                                       EPA815-F-00-014
                                                                          November 2000
                              Final Radionuclides
             National Primary Drinking Water R
EPA has revised (he current radionuclides regulation, whichihas been ingffect sinij^^^^y. requiring
new monitoring provisions that will ensure that all customers tof community water s
water that meets the Maximum Contaminant Levels for radionuclutes'in drinking water eijttffl
promulgated a standard for uranium as required by the 1986 eututm^ots to the Safe Drinking Water
Act. The current standards are: combined radium 226/228 of.5p^^^j^Kpss alpha standard for all
alphas of 15 pCi/L, not including radon and uranium; a con^)ined^sicfm^ip/4 mrem/year for beta
emitters. The new MCLfor uranium is 30 jug/L  This final rule will prs^ic^^jfroved health protection
for 420,000 persons through monitoring improvements for the combined raH^n^ 26/-22S standard fa
carcinogen) and for an additional 620, 000 persons throvghanew standardjlor uranium (a kidney toxin
and carcinogen) in drinking water.                          - -
                                                   s   '•.'c*gHl-:y. "
Final Standards                                         ';};  "

The regulated radioactive drinking watcpcontaminants are:
Contaminan|k
Combined
radium-226/-228
(Adjusted)
Gross Alpha
i
Beta Particle
and Photon
Radioactivity
Uranium
MCL;_J|||^0
5 pCl/L(I97Sji
15p€i/L(not
includmg radon or
uranium)
4 mrem/year
(look-up table)
30 ug/L
s^il?^:!?''
Natnrally occurs in
some drinking water
sources.
Naturally occurs in
some drinking water
sources.
May occur due to
contamination from
facilities using or
producing
radioactive materials.
Naturally occurs in
some drinking water
sources.
Health Effect (Year Promulgated)
Some people who drink water containing
radium -226 or -228 in excess of the
MCL over many years may have an
increased risk of getting cancer.
Some people who drink water containing
alpha emitters in excess of the MCL over
many years may have an increased risk of
getting cancer. (1976)
Some people who drink water containing
beta and photon emitters in excess of the
MCL over many years may have an
increased risk of getting cancer. (1976)
Exposure to uranium in drinking water
may result in toxic effects to the kidney.
Some people who drink water containing
alpha emitters in excess of the MCL over
many years may have an increased risk of
getting cancer. (2000)
Radionuclides Guidance
                                         IV-3
December 8. 2000

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 Background

 Radionuclides emit "ionizing radiation," a known human carcinogen, when they radioactively decay.
 Long-term exposure to radionuclides (see table above) in drinking water may cause cancer. As described
 in the Notice of Data Availability published on April 21, 2000, EPA has performed new health effects
 analyses based on improved scientific models and data. These new analyses demonstrate that the health
 effects analyses performed in 1991  generally understated the risks associated with the proposed
 Maximum Contaminant Level(MCL) changes. In fact, the new health effects analytical results indicate
 that radionuclides in drinking water are as risky (in some cases riskier) than originally estimated in 1976.
 For this reason, EPA has retained the more stringent 1976 MCLs in the final rule, sinceJBpproposed
 MCL changes were determined to be insufficiently protective of human healtJ
In addition, exposure to uranium in drinking water may cause toxieieffe
proposed an MCL of 20 ug/L, which was determined to be as.cfiselis feasib]
Contaminant Level Goal (MCLG).  Based on human kidney toxicity data
estimate of the costs and benefits of regulating uranium in drinking water,'HP A
benefits of a uranium MCL of 20 ug/L do not justify the co&sj, instead; EPA has detei
Hg/L is the appropriate MCL, since it maximizes the net benefits|lEi&eO(efits minus costs),
protective of kidney toxicity and carcinogenicity with an adequalRlBWgin of safety.
                                                          '
Provisions of the Final Radionuciides Rule
                                                         In 1991, EPA
                                                         .imum
In addition to the MCLs discussed above, this final rotes;
all water served to all customers meets the MCL^ferfj
will be accomplished by the requirement that^air future moi
entering the distribution system is tested. Under the old rule,
                                                             and OB its
                                  commuririper systems to ensure that
                                       driipmjg water. This provision
                                            irmed such that all water
                                          water systems only tested water
from a "representative point" in the distribution system. The oldSmonitoring requirements did not protect
every customer, since water quality ng^ vary significantly within the distribution system.
The monitoring frequency requirements have changed to be more consistent with the "Standardized
Monitoring Framework" that are used for other xfentkittg water standards.  This improvement will result
            •',;-.-          <     •',#£' ;         *.:':?&•'i*'    "
in increased-Cpnsistency iaflKmipoitBg requirements and will provide monitoring relief for those water
systems that.Iu«xfevery iow'conttiiiwmt levels.
 •*          . -. ••••"• »•*.  w          •jt-.x. •.""tifiltjjr '
             -  .(_• :*  . .•,            -.' '3y*^$f -
In addition, the itewirule corrects atoaaiiloriag deficiency in the 1976 framework for monitoring for
combined radium^
*i228.
                                       : old rule, it was assumed that radium-226 and gross alpha
levels could'be^isedto^^wi sn for radium-228. Since then, EPA has collected substantial evidence that
this assumption is false. Tl e^orrection involves separate monitoring requirements for radium-228 and
radium-226, further ensured jglbatdrinking water system customers will be protected from harmful
radioactive contaminant levels.

this final rule will apply only to community water systems, which are water systems with at least 15
service connections or that serve 25 or more persons year-round. EPA will further consider whether or
hot to regulate radionuclides levels in drinking water served by non-transient non-community water
systems, which are water systems that serve at least 25 of the same people more than six months per year,
such«S schools, churches, nursing homes, and factories that supply their own water.  EPA is consulting
with the National Drinking Water Advisory Council to determine the best course of action to take with
respect to regulating chronic contaminant levels for non-transient non-community water systems,
including  radionuclides.
December 8, 2000
                      IV-4
                                                                          Radionuclides Guidance


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Occurrence of Radionuclides in Drinking Water
Most drinking water sources have very low levels of radioactive contaminants ("radionuclides"). These
very low levels are not considered to be a public health concern. Of the small percentage of drinking
water systems with radioactive contaminant levels high enough to be of concern, most of the
radioactivity is naturally occurring.  Certain rock types have naturally occurring trace amounts of "mildly
radioactive" elements (radioactive elements with very long half-lives) that serve as the "parent" of other
radioactive contaminants ("daughter products"). These radioactive contaminants, depending on their
chemical properties, may accumulate in drinking water sources at levels of concern.  The "parent
radionuclide" often behaves very differently from the "daughter radionuclide" in the env|piment.
Because of this, parent and daughter radionuclides may have very different
patterns. For example, ground water with high radium levels tend.to have
versa, even though uranium-238 is the parent of radium-226.   ^&,>
                                                                                 • occurrence
                                                                               levels and vice
  est have sign
estern states
Most parts of the United States have very low "average radionuclide occmtpfce
sources. However, some parts of the country have, on average elevate,d0e"Vels of p
compared to the national average. For example, some partsjj
average combined radium-226/-228 levels. On the other ha
average uranium levels compared to the national average. Hd
are very low compared to the MCL throughout the United
that have been known to occur in a small number of drinking water
to be rare compared to radium-226, radium-228, and uranium.
                                                                            have
                                                     , .'IB-.,
                  ated
«eral, average uranium levels
    are other radionuclides
      ir occurrence is thought
                                                                     ave potential sources of
A very small percentage of drinking water systejas c.are"l
man-made radioactive contamination from facilities that;USejimaii^c|Uijrefor dispose of radioactive
substances.  Drinking water contamination May occur rttrough;=i

Since 1996, EPA's drinkuig water state revolving fund program has made available $3.6 billion to assist
dritiknig water systems with projects to improve their infrastructure. EPA has funded over 1000 loans
for prefects around the country.

For More information

For general information on radionuclides in drinking water, contact the Safe Drinking Water Hotline, at
1-800-426-4791, or visit the EPA Safewater website at http://www.epa.gov/safewater/ or the
radionuclides website at http://www.epa.gov/safewater/radionuc.html.
Radionuclides Guidance
                                              IV-5
               December 8, 2000

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 IV-B.  Question and Answers
 vvEPA
 Office of Water
           United Stiles
           environmen
                                                                  1:-  Ground Water
                                                                  ^Drinking Water
                                                                          EPA815-F-00-013
                                                                            jlpveinber 2000
Technical Fact Sheet:
Final Rule for (Non-Radon) Radionuclides in Drinking W^ter
1. What are we announcing?

EPA is promulgating the final drinking water standards for
combined radiiun-226/-228, (adjusted) gross alpha, beta
This promulgation consists of revisions to the 1976 rule, as

2. What are the requirements of this final rule?
                                                                 ionuclides
                                                            •hoton radioactive
                                                               991.
Community water systems (CWSs), which are public;'
residents regularly year round, are required to
monitoring and reporting.
                                                                      least 15 locations or 25
                                                                    the requirements for
Non-transient, non-community water syst|ps (NTN0WSs) wifBpl^^'regulated at this time. EPA will
further consider this matter and may gp)|f«nFmonitoring
Standf|fized Monitoring
                              ts will be phased-in between that date and the beginning of the next
                               k period, December 3 1 of 2007. "Phased-in monitoring" refers to the
factjat States will requir|pol|e fraction of water systems to complete their initial monitoring
re<|B'ements each year offiie period between the effective date (December 7, 2003) and the beginning of
t||||w cycle (DecemMlil, 2007). Water systems will determine initial compliance under the new
      ring requiremefits using the average of four quarterly samples or, at State discretion, using
                 ibered data. Compliance will be determined immediately based on the annual average
          ijj!ffimples for that fraction of systems required by the State to monitor in any given year or
                 from the grandfathered data. Water systems with existing radionuclides monitoring
data demonstrating that the system is out of compliance with new provisions will be out of compliance
on the effective date of December 7, 2003. Water systems with existing data that demonstrates
non-compliance with the current (1976) rule are currently in violation of the radionuclides National
Primary Drinking Water Regulations.
December 8, 2000
                                           IV-6
                                                                      Radionuclides Guidance

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4. Why is this rule significant?

This rule promulgates new monitoring provisions that will ensure that all customers of community water
systems will receive water that meets the Maximum Contaminant Levels for radionuclides in drinking
water. Under the 1976 rule, water systems with multiple entry points to the distribution system were not
required to test at every entry point, but rather to test at a "representative point to the distribution
system." While the 1976 requirement did ensure that the "average customer" was protected, it did not
ensure that all customers were protected. Under the new rule, all entry points will be tested and all CWS
customers will be ensured of receiving water that meets the MCLs for radionuclides in drinking water. In
addition, this requirement is more consistent with the monitoring requirements for other^jBiparable
drinking water contaminants.

This rule promulgates a new standard for uranium in drinking wat^r,,which,^lsfi^Bit4in reduced
uranium exposures for 620,000 persons. The uranium standard, which is requfiiiBdl^pfeiSafe Drinking
Water Act, will protect drinking water customers from uranium levels that may caa^maCseffects to the
kidney and will reduce cancer risk. In addition, the new mlepromulgatefr-separate friBiiraS^cf'
requirements for radium-228, which is expected to result in redu^dasposure to
monitoring correction is based on sound science and is necessS8TJi^!|^nsuring complianc'e^witfi the
combined radium-226/-228 standard.                       -
5. What health effects are associated with exposure to nwiionuclhie^fropsdrinking water?

Exposure to radionuclides from drinking water results in the increased risk of cancer. The radioactive
particles (alpha, beta and gamma particles) emitted by radionuclides are called "ionizing radiation"
because they ionize ("destabilize") nearby atoms as they travel thipugifcacell or other material. In living
tissue, this ionization process can damage chromosomes or omer^Sjslfef the cell. This cellular damage
can lead to the death of the cell or to unnatural reproduction of tliexe'll. When a cell reproduces
uncontrollably, it becomes a cancer. Certain elements accumulate in specific organs: radium (like
calcium) accumulates in the bones and iodine accumulates in the thyroid.

For uranium, we must consider not only the carcinogenic health effects from its radioactive decay and the
decay of its daughter products ("ladiotoxiciry"), but also damage to the kidneys from  exposure to the
uranium itself ("chemical toxicity?).-Exposure to elevated uranium levels in  drinking  water has been
shown to lead to changes in kidney,function that are indicators of potential future kidney failure.
6. What are t
ionudides in water?
Most drinking water sources Jiave Very low levels of radioactive contaminants ("radionuclides"), levels
low enough not to be considered a public health concern. Of the radionuclides that have been observed to
occur in drinking water sources, most are naturally occurring. However, contamination of drinking water
sources by anthropogenic ("human-made") nuclear materials also occurs. Naturally occurring
radionuclides are found in the Earth's crust and are created in the upper atmosphere. For example, trace
amounts of long-lived isotopes (e.g., uranium-238, which has a half-life of almost five billion years) have
been present in earth's crust since the crust first formed. As these long-lived trace radionuclides decay,
shorter-lived ("inore radioactive") daughter products are formed. Of particular concern are naturally
occurring uranium and the naturally occurring radium isotopes, radium-226 and radium-228, which have
been observed to accumulate to levels of concern in drinking water sources.

Most of the naturally occurring radionuclides are alpha particle emitters (e.g., the uranium isotopes and
radium-226), but naturally occurring beta particle emitters do occur (e.g., radium-228 and potassium-40).
Certain rock types contain trace amounts of the radioactive isotopes of uranium, thorium, and/or
actinium. As these parent rocks weather, the resulting clays and other aquifer-forming materials may
Radionuclides Guidance
                 IV-7
December 8, 2000

-------
 become a source of naturally-occurring radionuclides to drinking water sources. Other naturally
 occurring radionuclides include tritium, a beta particle emitter, which forms in the upper atmosphere
 through interactions between cosmic rays (nuclear particles coming from outer space) and the gases
 comprising the atmosphere. Tritium can be deposited from the atmosphere onto surface waters via rain or
 snow and can accumulate in ground water via seepage. Tritium is also formed from human activities, as
 described below. Natural tritium tends not to occur at levels of concern, but contamination from human
 activities can result in relatively high levels.

 The man-made radionuclides, which are primarily beta and photon emitters, are produced by any of a
 number activities that involve the use of concentrated radioactive materials. These radioaisteve materials
 are used in various ways in the production of electricity, nuclear weapons, nuclear medpihes used in
therapy and diagnosis, and various commercial products (such as televisio:
as in various academic and government research activities. Release'of
environment, which may include drinking water sources, are primarily the res
storage, leaks, or transportation accidents,                             1

7. How many people and how many systems will be affect^&^ tbfer rule?
                                "detectors), as well
                                muclides to the
                                       waste
Higher levels of radionuclides tend to be found more in grouri)
sources, likes rivers and lakes. While most water systems do|0ot
there are some areas of the country that have levels significihtly hi
For example, some areas of the Mid-West have elevai
have elevated uranium levels compared to the rest ^MSHUll.States
expected to result in roughly half of one percen^fife
lower radium in their drinking water. The uranium
percent of CWSs needing to take measures.to reduce ulanium
shows the estimated number of CWSs that would be affected by*
served by these public water systems/?;
                rule
   :s than in surface water
    We radionuclide activities,
      j national average levels.
          >e Western States
       monitoring for radium is
    heeding to take measures to
    ,ult in slightly less than one
nking water. Table 1 below
 and the estimated population
 Table I. Estimates of the Co
 and tbe PojiMtioe Served
        ould Need to Mitigate Contaminant Levels
                                      Number of CWSs Affected
                       Total Population Served
 8. Hour much will this nil* <*»**?
Over 96% of the cost of this final rule is expected to come from the mitigation of radionuclide levels
through treatment, purchasing water, developing alternate water sources, and other compliance measures.
Table 2 below shows the total annualized costs of mitigation, monitoring, reporting, recordkeeping, and
                     rule.
December 8, 2000
IV-8
         Radionuclides Guidance

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Table 2. Total Nat JonalAnnualized Costs oft he Radionuclides Rule ' ",:V ' •':••:..• ::;. "'.' ''' . •
(Mitigation, monitoring, reporting, recordkeeping, and administration)
Regulatory Action
Radium-228 Monitoring Correction, Mitigation Costs
Uranium MCL of 30 ng/L, Mitigation Costs
New Monitoring, Reporting, Recordingkeeping, and Administration Costs for all
Radionuclides
Annual Costs
~ $ 26 million
- $ 50 million
~ $ 5 million
*•* i-
               For systems that need to take corrective action to comply wij|||he.B*?iiV rule, the annual
               costs per system will range from $9,000 per year for the SBttiIi^te(^nmunity water
               systems to over $150,000 annually for systems-serving 3,3tfCfipiand over $0.5
               million annually for larger systems.
               For the small percentage of households that into servedjfcy water systei
               required to take corrective actions because ofithi|||||e, it is estimated tha
               served by typical large water systems will exptejae^^mcreased water bills of less than
               $30 per year and that households served by typifea^^Hfi^ter systems (those serving
               10,000 persons or fewer) will experience mcreased'i$i^^||^of $50 - $100 per year.
               Costs will vary depending on the system-size.       "<•'••
                                                 ;.  w-y,          • -.-gji:, •
9. What are the benefits of this rule?                      	
                                                          . : _ \

               The requirement for separate radium-228 monitoringi&expected to result in the
               avoidance of 0.4 cancer cases per year,  with estimated monetized health effects benefits
               of $ 2 million annually. Water mitigation for radium also tends to reduce iron and
               manganese levels  and hardness, which also has significant associated benefits.

               The kidney toxicity, benefits tbrjthe uranium standard can not be quantified because
                                  ; health effects models at levels near the MCL. In addition to these
                                  p: toxicity benefits, 0.8 cancer cases per year are expected to be
              "avoided, with estimated monetized cancer health effects benefits of $ 3 million annually.
               Watiar mitigation for uranium also removes other contaminants, which has associated
               benefits.

10. Is there funding associated with this rule?

Sinws 1996, the Drinking WaterState Revolving Loan Fund has made over $3.6. billion available for
loans to help water systems improve their infrastructure. This program has now made over 1000 loans.
EPA also provides funding to States that have primary enforcement responsibility for their drinking water
programs through the Public Water Systems Supervision (PWSS) grants program. Other federal funds are
available through Housing and Urban Development's Community Development Block Grant Program,
and the Rural Utilities Service of the U.S. Department of Agriculture.

11. How did EPA consult with stakeholders?

In 1997,  EPA conducted a public meeting regarding the finalization of portions of the 1991 radionuclides
proposal. This meeting was advertised in the Federal Register. During the meeting, we discussed a range
of regulation development issues with the stakeholders, including the statutory requirements, court
stipulated agreement, MCLs for each of the radionuclides, the current and proposed monitoring
Radionuclides Guidance
IV-9
December 8. 2000

-------
frameworks, and new scientific information regarding health effects, occurrence, analytical methods, and
treatment technologies. The presentations generated useful discussion and provided us feedback
regarding technical issues, stakeholder concerns and possible regulatory options. Participants in the
stakeholder meeting included representatives from water utilities, environmental and citizens groups,
State drinking water programs  and health departments, other federal agencies, and other groups.

In addition, during the regulation development process, we gave presentations on the radionuclides
regulation at various professional conferences, meetings between State programs and EPA Regions, the
American Water Works Association's Technical Advisory Workgroup (TAW), and at Tribal meetings in
Nevada, Alaska, and California. Finally, we held a one-day meeting with associations thafeepresent
State, county, and local government elected officials on May 30, 2000 and diss^ssedJjplPupcoming
drinking water regulations, including radionuclides.                     /•*.' . ••^'^
                                                          ..'*•!:''
                                                           ;i!::^i. 7      X'
Stakeholders were also asked to comment on a variety of issues iri'the April
Availability. We utilized the feedback received from the stallholders
comments from the NODA in developing the final radionucttles rule.  /
                                  r   °                yist.      *..--.?
12. Where can the public get more information about th
                                                               ioouclides rule?
For general information on radionuclides in drinking waterr£0nt
(800) 426-4791, or visit the EPA Safewater website at J
radionuclides website at http://www.epa. gov/safewaterfeadiDPuc.htnil. "V
                                                                     Drinking Water Hotline, at
                                                                         rater/ or the
In addition to this technical fact sheet, the folioi	
                                  '       &y
at EPA's web site on radionuclides in drinkiqgjwater:
               Federal Register notic%afiihe Notice-of Data Al
               A Technical Supportjrocument r. •
               Consumer Fact Sh&jjj&ri RadioancHdes in Dfmking Water
               The Economic Analysis for the^Smal rule
                                                              fact sheets are available to the public
A copy of A&i'iederal Register OOtioe of the flail regulation, the Notice of Data Availability, or
supporting matepal can be obteiip||5|contacting the Safe Drinking Water Hotline at (800) 426-4791.
The Safe Drioldt^^Pater Hotlindvi|^pMonday through Friday, excluding Federal holidays, from 9:00
a.m. to 5:30 pjn|Ba$toni Time.
                                >Y4"»^
                                 »' * I
December 8, 2000
                                             IV-10
Radionuclides Guidance

-------
        United States
        Environmental Protection
        Agency
Office of Water
(4606)
EPA816-D-00-002
December 2000
v>EPA Implementation Guidance
        for Radionuclides
                          t?:
        Appendices A -

-------

-------
Table of Contents
Appendix A   Violation Tables for Data Management and Enforcement Purposes  	  A-l
Appendix B    Sample Extension Agreement	  B-1
Appendix C    Primacy Revision Crosswalks	••,«;-•	C-l
Appendix D    SDWIS-Fed DTP Reporting Requirements Guidance	 D-l
Appendix E    Statement of Principles— Guidance on Audit Law Issues	  E-I
Appendix F   Rule Presentations	  F-l
Appendix G   Rule Language	 G-l
Appendix H   Comparison of Derived Values of Beta and Photon Emitters	 H-l
References
          H-9
Radionuclides Guidance
December 8, 2000

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                             This page has-been intemi
December 8, 2000
Radionuclides Guidance

-------
Appendix A
Violation Tables for Data
Management and
Enforcement Purposes

-------
                                  This pageiintention
                         ' '?
                         f
December 8, 2000
Appendix A-2
Radionuclides Guidance

-------
For additional information on the Violation Tables for Data Management and Enforcement Purposes
please contact:

Kate Anderson
Associate Division Director
Office of Regulatory Enforcement
Water Enforcement Division
(202)564-4016
e-mail: anderson.kate@epamail.gov
Radionvclides Guidance
Appendix A-3
December 8, 2000

-------
                                  This paggihtentionally:l
December 8, 2000
Appendix A-4
Radionuclides Guidance

-------
Appendix B
Sample Extension
Agreem^it

-------
                                 This Page Intentions^ l^dft Blank.
December 8, 2000
Appendix B-2
Radionuclides Guidance

-------
                                                      'ft-. ;
         tlackr 40 CFR M&12, Slates s«m adopt
             in 2 years of the fiml rale
         complete a«rf find primacy
                                     Rule
                         not submitted a
                                     For
Radionuclides Guidance
Appendix B-3
December 8, 2000

-------
EXTENSION AGREEMENT
On December 7, 2000, the U.S. Environmental Protection Agency (EPA) published the final
Radionuclides Rule. This rule amends the National Primary Drinking Water Regulations, 40 CFR Part
141 and the regulations for implementation of the National Primary Drinking Water Regulations, 40 CFR
Part  142. Provisions of the rule take effect on December 7, 21, 2003.

The April 28, 1998 revisions to the Primacy Rule extend the time allowed for States to adopt new Federal
regulations from 18 months to 2 years. Therefore, the State must adopt regulations pertaifiiirig to the
Radionuclides Rule and submit a complete and final primacy revision application by December 7, 2002
unless it requests an extension of up to 2 years to adopt the new or revised
                                                                                  EPA
                                                                                  indicated in
Until the State Primacy Revision Application has been submiR«i.rthe State
Regional office will share responsibility for implementing th^jprimary pr
the extension agreement. The State and the EPA Regional $pce shoulddiscuss the
address terms of responsibility in the agreement.  The StateiaiSl||EE^ishould be vieweffiSBjIpiBPi's in this
effort, working toward two very specific public health-relate^i^olj4||?pjhe first goal is to achieve a high
level of compliance with the regulation. The second goal is to fiB||iit«puccessful implementation of the
                                                       ' ;!\^r^43^BST-"*''1
regulation during the transition period before the State has uiterimiipumacpfbr the rule. In order to
accomplish these goals, education, training, and technical assistance '?^:rtei(lito be provided to water
suppliers on their responsibilities under the Radionuclides Rule.
This document will record the terms of a Prima
for the Radionuclides Rule, and shall remain j^ffective from ^
                                                             ent between the State and the EPA
                                                          ateitius agreement is signed until either
December 7,2002 or the date the State's primacy applicationl^^fed under 40 C.F.R. §142.12. To
retain primacy the State must submit a filial and apprbvable Priiaacy"Revision Application incorporating
the above-referenced provisions of thefederal Register to EPA by December 7,2002, or no later than
December 7, 2004, if the State has been granted-an extension.
December 8, 2000
                                         Appendix B-4
Radionuclides Guidance


-------
(Regional Administrator!
Regional Administrator
U.S. EPA Region {Region!
(Street Address}
(City, State, Zipl

RE: Request/approval for an Extension Agreement
Dear (Regional Administrator};
     ==^^=^==      '" " ....... "~ ........ " ..... '" " "^                                      •

       The State of (State! is requesting an extension to the date-that final
EPA for the Radionuclides Rule until {insert date - no later than December 7.
CFR 142.12 and would appreciate your approval. Staff of tixeJ
                                                                             fyisions are due to
                                                                                a] lowed by 40
conferred with your staff and has agreed to the requirements listed betevv for this extenMori This
extension is being requested because the State of (State):
                                                          i > :'-<;  N
Q     Is planning to group two or more program revisions into^asingjillegislative or regulatory action.

Q     Currently lacks the legislative or regulatory authority to enforce theJaew or revised requirements.
Q     Currently lacks adequate program capability to implement the flew or revised requirements.

       (State Department/Agency} will be implementing the Radionuclides Rule within the scope of
its current authority and capability as outlined in the six areas identified in 142.12(b)(3Xi-vi):

i) Informing PWSs of the new EPA (and upcoming State) requirements and that EPA will be
overseeing implementation of the requirements until EPA approves the State revision.

State
		:, ipbYide copies ofitegulation and guidance to other State agencies, PWSs, technical
               assistance providers|associations, or other interested parties.
	  	   Educate arid coordinate with State staff, public water supplies (PWSs), the public, and
               other water associations about the requirements of this regulation
	  	   Notify affected systems of their requirements under the Radionuclides Rule.
	  	   Other    r ;'•    ;  :

ii) Collecting, storing  and managing laboratory results, public notices, and other compliance and
operation data required by the EPA regulations.
State  EPA
               Devise a tracking system for PWS reporting pursuant to the Radionuclides Rule.
               Keep States informed of SDWIS reporting requirements during development and
               implementation.
               Report Radionuclides Rule violations and enforcement information to SDWIS as
               required.
               Other
Radionuclides Guidance
                                         Appendix B-5
December 8, 2000

-------
 iii) Assisting EPA in the development of the technical aspects of the enforcement actions and
 conducting informal follow-up and violations (telephones calls, letters, etc.).
 State   EPA
               Issue notices of violation (NOVs) for treatment technique and monitoring/reporting
               violations of the Radionuclides Rule
               Provide immediate technical assistance to PWSs with treatment technique and/or
               monitoring/reporting violations to try to bring them into compliance.
               Refer all violations to EPA for enforcement if they have not been resolydltwithin 60
               days of the period that triggered the violation. Provide information as-requested to
               conduct and complete any enforcement action referred to
               Other                                         :
iv) Providing technical assistance to public water systems.
State  EPA
                                                                 ;Iides rule requirements.
                                                                     irrespondence to PWSs.
                                                                        ceded to ensure
Conduct training within the State for PWSs
Provide technical assistance through writter
Provide on-site technical assistance to PWSs'as:
compliance with this regulation.
Evaluate requests for alternate recyGie;it^oniaecations irr®i|pedient manner.
Coordinate with other technical assistaiK5Ci^«^|iders and organization to provide accurate
information and aid in a timeljflhanner. i.'•'"-:-<"|;ff-•.,. ./
Other                    .               ' '*' '"'"*"'"
v) Providing EPA with all inform*iiairpresciibed by the State Reporting Requirements in 142.15.

State  EPA              .  \  . :,.'        . ^7 . ..
	     ,-• :=  Report any vioiatioos incurred^f^Bs for these regulations each quarter.
	  ...  '. 'p.j-lUsport any enforcement actionrtaiken against PWSs for these regulations each quarter.
	     ' ''". "Iteport any varianpeSiOr exemptions granted for PWSs for these regulations each quarter.
vi) For States whose
implement the new or
capablTity deficiency.
             for an extension is based on a current lack of program capability to
                   irements agrees to take the following steps to remedy the
State  EPA
               Acquire additional resources to implement these regulations (List of specific steps being
               taken attached as (Appendix A}).
               provide quarterly updates describing the status of acquiring additional resources.
               Other
December 8, 2000
                           Appendix B-6
Radionuclides Guidance

-------
I affirm that the {State Department/Agency} will implement provisions of the Radionuclides Rule as
outlined above.
(Agency Director or SecretarYl
                                     Date
 (Name of State Agency}
I have consulted with my staff and approve your extension for the-aforementioned regulation. I affirm
that EPA Region {Region} will implement provisions of the Radionuclides Rfeie as outlined above.
Regional Administrator
EPA Region {Region}
This Extension Agreement will take effect upon the date of the last signature.
                                                    ••  '     ', ',.';: .,'    •
Radionuclides Guidance
Appendix B-7
December 8, 2000

-------
                             This page has teen intentio
December 8, 2000
Appendix B-8
Radionuclides Guidance

-------
Appendix C
Primacy
Crosswalks

-------
                                                                      •....T; *<,.  - . _&,-• •
                             This page hasieen intentton^ly l^biank.
                                          •               "       '
December 8, 2000
Appendix C-2
                                                                              Radiomiclides Guidance

-------














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Systems must collect quarterly samples for beta emitters and iodine-
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point to the distribution system (hereafter called a sampling point),
beginning within one quarter after being notified by the State.
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contaminated by effluents from nuclear facilities must continue to
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annual average (computed quarterly) less than or equal to 15 pCi/L,
the State may reduce the frequency of monitoring at that sampling
point to every 3 years. Systems must collect all samples required in
paragraph (b)(2) of this section during the reduced monitoring period.
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For systems in the vicinity of a nuclear facility, the State may allow
the CWS to utilize environmental surveillance data collected by the
nuclear facility in lieu of monitoring at the system's entry point(s),
where the State determines if such data is applicable to a particular
water system. In the event that there is a release from a nuclear
facility, systems which are using surveillance data must begin
monitoring at the community water system's entry point(s) in
accordance with paragraph (b)(2).













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Community water systems designated by the State to monitor for beta
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waiver from the monitoring frequencies specified in paragraphs (b)(l)
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Community water systems may analyze for naturally occurring
potassium-40 beta particle activity from the same or equivalent sample
used for the gross beta particle activity analysis. Systems are allowed
to subtract the potassium-40 beta particle activity value from the total
gross beta particle activity value to determine if the screening level is
exceeded. The potassium-40 beta particle activity must be calculated
by multiplying elemental potassium concentrations (in mg/L) by a
factor of 0.82.













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If the gross beta particle activity minus the naturally occurring
potassium-40 beta particle activity exceeds the screening level, an
analysis of the sample must be performed to identify the major
radioactive constituents present in the sample and the appropriate
doses must be calculated and summed to determine compliance with
§ 14 1 .66(d)(l ), using (d)(2). Doses must also be calculated and
combined for measured levels of tritium and strontium to detennine
compliance.
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Systems must monitor monthly at the sampling point(s) which exc
the maximum contaminant level in § 141,66(d) beginning the mon
after the exceedance occurs. Systems must continue monthly
monitoring until the system has established, by a rolling average o
monthly samples, that the MCL is being met. Systems who establi
that the MCL is being met must return to quarterly monitoring unti
they meet the requirements set forth in paragraphs (b)(l)(ii) or
(b)(2)(i) of this section.
















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General monitoring and compliance requirements for radionuclide
















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The State may require more frequent monitoring man specified in
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samples at its discretion. The results of the initial and confirmatiG
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Each public water system shall monitor at the time designated by t
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Compliance: Compliance with 141.66 (b) through (e) will be
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in violation of the MCL.














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For systems monitoring more than once per year, compliance with
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point. If the average of any sampling point is greater than the MC
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For systems monitoring more than once a year, if any sample resul
will cause the running average to exceed the MCL at any sample
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MCL for combined radium-226 and 228.
The maximum contaminant level for combined radium-226 and
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value is determined by the addition of the results of the analysis fo
radium-226 and the analysis for radium-228.




















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The average annual concentration of beta particle and photon
radioactivity from man-made radionuclides in drinking water musi
produce an annual dose equivalent to the total body or any internal
organ greater than 4 millirem/year (mrem/year).
                                                                                                                                                                    
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Except for the radionuclides listed in Table A, the concentration of
man-made radionuclides causing 4 mrem total body or organ dose
equivalents must be calculated on the basis of 2 liter per day drinkin
water intake using the 168 hour data list in " Maximum Permissible
Body Burdens and Maximum Permissible Concentrations of
Radionuclides in Air and in Water for Occupational Exposure, " NB
(National Bureau of Standards) Handbook 69 as amended August
1963, U.S. Department of Commerce. This incorporation by referen
was approved by the Director of the Federal Register in accordance
with 5 U.S.C. 552(a) and 1 CFR part 51. Copies of this document a
available from the National Technical Information Service, NTIS
ADA 280 282, U.S. Department of Commerce, 5285 Port Royal Ro
Springfield, Virginia 22 161. The toll-free number is 800-553-6847.
Copies may be inspected at EPA's Drinking Water Docket, 40 1 M
Street, SW., Washington, DC 20460; or at the Office of the Federal
Register, 800 North Capitol Street, NW., Suite 700, Washington, D<
If two or more radionuclides are present, the sum of their annual do:
equivalent to the total body or to any organ shall not exceed 4
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Table A - Average Annual Concentrations Assumed to Produce A
Total Body or Organ Dose of 4 mrem/yr
Radionuclide Critical Orean oCioer Liter
Tritium Total body 20,000
Strontium-90 Bone marrow 8



















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Compliance dates for combined radium 226 and 228, gross alpha
particle activity, gross beta particle and photon radioactivity, and
uranium: Community water systems must comply with the MCLs
listed in paragraphs (b), (c), (d) and (e) of this section beginning
December 7, 2003 and compliance shall be determined in accordi
with the requirements of § 141.25 and § 141.26. Compliance wit!
reporting requirements for the radionuclides under Appendix A to
Subpart O and Appendix A and B to Subpart Q is required on
December 7, 2003.




















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Best Available Technologies (BATs) for Radionuclides.
The Administrator, pursuant to section 1412 of the Act, hereby
identifies as indicated in the following table the best technology
available for achieving compliance with the maximum contaminai
levels for combined radium-226 and and radium-228, uranium, gr
alpha particle activity, and beta particle and photon radioactivity.
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APPENDIX A TO SUBPART O OF


















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MCLinmg/L: 15 pCi/L
MCL in CCR units: 15
MCLG: 0
Major sources in drinking water:
Health effects: Certain minerals
of radiation known as alpha radii
containing alpha emitters in exce
have an increased risk of getting
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Tier of Public Notice Required Citation
310 141.25 (a), 141,


















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Radionuclides which adopts the requirements specified in
1 4 1 .26(a)(2)(ii)(C) of this chapter must contain the follow
addition to the general primacy requirements enumerated i
including that State regulations be at least as stringent as tl
requirements):















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A monitoring plan by which the State will assure all systems <
the required monitoring within the regulatory deadlines. Stat<
update their existing monitoring plan or use the same monitor
submitted for the requirements in § 142.l6(e)(5) under the Na
Primary Drinking Water Regulations for the inorganic and oq
contaminants (i.e. the Phase II/V Rules). States may note in tl
application any revision to an existing monitoring plan or noti
same monitoring plan will be used. The State must demonstn
the monitoring plan is enforceable under State law.


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(OPTIONAL - STATES THAT PLAN TO ALLOW VARIANCES AND K





















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Variances and exemptions from the maximum contaminant levels
Combined Radium-226 and Radium-228, Uranium, Gross alpha
particle activity (Excluding Radon and Uranium), and Beta Particli
and Photon Radioactivity.
The Administrator, pursuant to section 141 5(a)( 1)(A) of the Act,
hereby identifies the following as the best available technology,
treatment techniques, or other means available for achieving
compliance with the maximum contaminant levels for the
radionuclides listed in § 14 1 .66 (b), (c), (d), and (e) of this chapter,
the purposes of issuing variances and exemptions, as shown in
§ 1 41. 66 (g) Table B.
In addition, the Administrator hereby identifies the following as th
best available technology, treatment techniques, or other means
available for achieving compliance with the maximum contaminan
levels for the radionuclides listed in §141.66 (b), (c), (d), and (e) o
this chapter, for the purposes of issuing variances and exemptions '
small drinking water systems, defined here as those serving 10,000
persons or fewer, as shown in § 141.66 (h) Tabk D.





















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any treatment technology identified in Table A of this section,
paragraph (1), or in the case of small water systems (those serving
10,000 persons or fewer), § 141.66 (h) Tables C and D, as a condit
for granting a variance except as provided in paragraph (a)(3) of th
section. If, after the system's installation of the treatment technolo
the system cannot meet the MCL, that system shall be eligible for i
variance under the provisions of section 1415(a)(l)(A) of the Act.
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[fa community water system can demonstrate through comprehensive
engineering assessments, which may include pilot plant studies, that
the treatment technologies identified in this section would only
achieve a de minimus reduction in the contaminant level, the State
may issue a schedule of compliance that requires the system being
granted the variance to examine other treatment technologies as a
condition of obtaining the variance.














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If the State determines that a treatment technology identified under
paragraph (a)(3) of this section is technically feasible, the
Administrator or primacy State may require the system to install
and/or use that treatment technology in connection with a compliance
schedule issued under the provisions of section 1415(a)(l)(A) of the
Act. The State's determination shall be based upon studies by the
system and other relevant information.














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The State may require a community water system to use bottled water,
point-of-use devices, point-of-entry devices or other means as a
condition of granting a variance or an exemption from the
requirements of §141.66 of this chapter, to avoid an unreasonable risk
to health.














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Community water systems that use bottled water as a condition for
receiving a variance or an exemption from the requirements of
§141.66 of this chapter must meet the requirements specified in either
paragraph (g)( 1 ) or (g)(2) and (g)(3) of § 1 42.62.














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-------
Appendix D
SDWISfFed
TF Reporting
Guidance

-------
                             This page has fceea iateationally left blank.
December 8, 2000                           Appendix D-2                      Radionuclides Guidance

-------
 v>EPA
           United States
           Environmental Protection
           Agency
Office of Water
(4606)
EPA816-D-00-005
December 2000
           State Reporting Guidance
           for Radionuclides
Radionuclides Guidance
            December 8, 2000

-------

-------
                                  Draft for Comment
Table of Contents
Disclaimer	 2
I.      Introduction	. .5.;.. • .'-.-•.	 ^
II.     Federal Monitoring Requirements		iii,	 4
                                                ••••           •'    rife*'.- •••-  •
III.    Federal Reporting Requirements	 5
       A.    Compliance Period	:ii!:..	,:.	;	 5
       B.    Violations	.;.	 6
       C.    Returned to Compliance and Enforcement Actions	 7
       D.    SNC Definitions	 ..^i.	 iii	 7
IV.    SDWIS/FED Data Transmittal	 9
V.     Sources for Additional Information	 II


Appendices

Appendix A: Monitoring, Reporting, and Compliance Determination Examples	 12
Radionuclides Guidance
Appendix D-1
December 8, 2000

-------
                                          Disclaimer
This document provides guidance to EPA Regions and States exercising primary enforcement responsibility
under the Safe Drinking Water Act concerning how EPA interprets  the reporting  requirements for
radionuclides monitoring. This guidance reflects the reporting corrections to the Radionuclides Rule which
was published as a final rule in the Federal Register on December 7, 2000.

This draft guidance document is based on the Final Radionuclides Rule and is not finafeEPA policy. The
materials contained in this guidance are subject to change to address commentj&eeeiv|ia»n this draft. After
modification, this guidance will be reissued in final form.                . *?i
 December 8, 2000                           Appendix D-2                     Radionuclides Guidance

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 I.
Introduction
        This document addresses the requirements for State reporting to EPA and the definitions of
 monitoring, reporting, violations and returned to compliance data under the Radionuclides rule.  Such
 reporting is required under Section 1445 of the Safe Drinking Water Act (codified at Section 142.15 of Title
 40 of the Code of Federal Regulations). The goal of this document is to obtain consistency in the manner
 in which radionuclides violation  data are reported to EPA via the Safe Drinking Water Information
 System/Federal Version (SDWIS/FED) Data Transfer Format (DTP).


        This guidance document is designed for use by State program officials; fiowever, States may at their
 discretion share components of this guidance with PWSs, drinking water laboratories, and others in the
 drinking water community.


        For the purposes of this document, "State" means each of the fifty States, the District of Columbia,
 Guam, the Commonwealth of Puerto Rico,  the Northern Mariana Islands, the Virgin Islands, American
 Samoa, the Trust Territories of the Pacific Islands, and any Indian Tribe which has treatment as« State status
 under Section 1451 of the Safe Drinking Water Act for this prpgM0iiSs=
Radionuclides Guidance
                                 Appendix D-3
December 8, 2000

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II.     Federal Monitoring Requirements

       This section of the guidance provides the monitoring requirements for Radionuclides. Radionuclides
monitoring and reporting will be based on the following contaminants:

       Gross Alpha, excluding Radon & Uranium
       Combined Radium -226 & -228
       Combined Uranium -234, -235 & -238
       Man-Made Beta Particle and Photon Emitters

       Initial entry point to the distribution system monitoring for radionuelides begins December 7,2003
and ends December 31, 2007.  A radionuelides violation mast be reported;fot any.^tem that fails to
complete ANY of the following activities during the compliance period:  •=          1^'V.v-         :?

       Using the appropriate sampling procedures in accortSaraoe^lfh Sections 141.25 a^|141:44
       Collecting the required number of samples during th^speejfwdpme frame, in accordance
       with Sections 141.25 and 141.44               "        \f-     ;
                                                             "'-'   '  ' C, "'";"

       Ensuring samples are analyzed properly in accpwlaace with Sections 141.15, 141.16 and
       141.25                           _.4/:     "" '-.";";

       Submitting all required monitoring information on-time in accordance with Sections 141.31
       and 142.15
December 8, 2000                          Appendix D-4                     Radionuclides Guidance

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HI.     Federal Reporting Requirements

        This section discusses the SDWIS/FED radionuclides rule reporting requirements for public water
system (PWS) monitoring programs under the SDWA.  Violation and returned to compliance reporting
requirements for each violation type are defined.

The following table contains the permissible contaminant codes for SDWIS/FED radionuclides reporting.
SDWIS/FED Radionuclides Contaminant Codes
Contaminant Name
Gross Alpha, Excl. Radon & Uranium
Combined Radium -226 & -228
Combined Uranium -234, -235 & -238
Man-Made Beta Particles and Photon Emitters
\-'
SDWIS/FED Contaminant Code
w •-.; . • .— A^
.4000 . ,v4i&X,
•. • " * H^r^^v
- •'" J*''"~!''Mi5«'T' '*
:•"• . '. S1-*^ s •
4010 -. ;t;"rC. ."
4006
'.:'"&;' ,4101
        A.      Compliance Period
       Compliance period can have two  distinct definitions, one definition when  we refer  to the
Standardized Monitoring Framework (SMF), and a completely separate definition when we refer to
SDWIS/FED.

       Under the SMF, a compliance period means a three-year period of time (calendar year based) within
a nine-year compliance cvelg.    ';  -

       In SDWIS/FED, a compliance periodmeans the period of time during which monitoring was to have
been performed, such as a quarter, a year, etc.  For example, assume a PWS is required to monitor for
contaminant XeacKcalendar quarter,  if this PWS fails to conduct the required monitoring for contaminant
X for the first calendar quarter of 2G02, a M/R violation is incurred.  When this M/R violation is reported
to SDWIS/FED, the State must supply the beginning date of the compliance period, and the ending date of
the compliance period. The beginning date of the compliance period in this example would be 0/01/0002,
the ending date of the compliance period would be 03/31/2002.


       In an effort to eliminate the confusion between the SMF compliance period and the SDWIS/FED
compliance period in this document, the SDWIS/FED compliance period will be hereafter referred to as a
monitoring period.
Radionuclides Guidance
Appendix D-5
December 8, 2000

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        B.      Violations

        EPA views violations on  a  system specific basis, therefore,  violations  must be reported to
SDWIS/FED by system only (no reporting by sampling point will be accepted). For EPA purposes, each
system  can  be  in violation only one time,  for each type of violation, for each contaminant, for each
compliance period — even though the PWS may have had multiple violations of the same type and for the
same contaminant and monitoring period, at multiple sampling points. In choosing which of the sampling
points to report a same type violation for, always report the more severe violation.

                                                                              •'tfiS?'
        States must report ONLY Federal maximum contaminant level (MCL) and monitoring and reporting
(M/R) violations to SDWIS/FED within 45 days after the end of the quarter .|n|wilici§me violation occurs.
Violations that are the result of more stringent State MCLs, more|^ngent^ite«te^ling frequencies, or
for contaminants not regulated at the Federal  level, etc. should N0T be repo^^l^^^S/FED. Failure
to comply with this requirement will translate into more PWSs^eing identifiers'Vi'i^^^feSDWISHED
than are actually in violation of the Federal requirements, anj£in the wortttase, ma3^^^p|FWSs being
incorrectly classified as a Significant Non-Complier.      I r >      -"'"''
                                                     \- "f    T  ;                 -.^.s-ak ».. . .. -

Violations of the Radionuclides Rule and the Public NotificationJti|e||p|;equired to be linked, refer to the
State Implementation Guidance for the Public NotificationjfrN) Ra^^jjj^i&i information on reporting
violation information to the general public.                      '""-Iffif:?=f;'
                                                 ::.:.  '                "•&?
SDWIS/FED Reporting will be based on the foll(^ogdcfinitionaand violation type codes (in parenthesis).
                                                   .-  .:  ••• / ft:.
                                                  •   '  '••  '•"t\) - ~"3''""~
               MCL Average Exceedance Violation (02)    > ' ^J|K


               At a sampling site, the-cotnputed running annual average exceeds the MCL or; any
               one sample causes.tbe annual :«verage to exceed the MCL (e.g. 1  sample  result
               exceeds 4 times theSvlCL).     j     ; ::
             .: '.'••-         ,  !     •:;:,-          'I'.-- '' '/- I' '
                          '     ",\- -;..
               Mottitoring"«ndl|(^prting Violation (03)
               , •  • ' "••            *•;*;*
               At a sampling site, faUure to: complete the initial round of sampling; conduct any
                       mpling: conduct confirmation sampling, when required; or accurately
               report the«i|alytical result of a regular or confirmation sample to the State.

    *"  For each violation listed above, the State must report the following data to SDWIS/FED.

...........  »       A unique PWS-ID

       »      :& unique violation ID

       *•       A code identifying the contaminant for which the violation applies

       >•       A code describing the type of violation



December 8, 2000                           Appendix D-6                      Radionuclides Guidance

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               Calendar date of the beginning of the monitoring period


               Calendar date of the end of the monitoring period


               Analytical Result (Running Annual Average) causing the violation (for MCL violations
               only).
        C.     Returned to Compliance and Enforcement Actions
        When a MCL or M/R violation has been incurred, it must be reported-to^S^&fEED. In addition,
 the State must inform EPA when that violation has been appropriately resolved. KSfiliileli^fo Compliance
                                                   ill    *(   ^  ^ ,       ^ .. .„,, •:jv-(^ %".;v % •   .•"*' :"
 (RTC) is defined for an MCL violation as subsequent monitoring shows'system is belcNifi^KldC. RTC is

 defined for an M/R violation as system is reporting in accordance-whir requirements.
        In addition, all formal enforcement actions taken against \il!aliohs of this rule are required to be
 reported to SDWIS/FED. Both "returned to compliance" -and fonnAi&orieanents must be linked to the
 specific violation(s) they address. The following describes the appropriate ways avwhich enforcement and
 follow-up actions, formal and informal (including returned to compliance), may be linked to Radionuclides
 rule violations:
        Associated Violation IDs (Y5000) - FY & VIOLATlOHlKNtJMBER.

        Entering the specific violationB5(s) to which the enforcement action is related will establish
        a link between the  enforcement record and each violation record matching the specific
        violation ID. If no links are established (reported violation IDs not found/matched on the
        data base) the enforcement record will be posted.

        Associated Violation Contaminant Groups (Z5000) - TYPE, CONTAMINANT, Monitoring
        PERIOD BEGIN DATE (M(5pAY & YR)

        Entering the Radionuclides violation type code, the contaminant code and the begin date of
        the monitoring period begin "date will establish a link between the enforcement action and
        all Radionuclides violations which exactly match the enforcement link data. If no matches
    '   are found, the enforcement record will be posted.

 Refer to the SDWIS/FED Data Entry Instructions for more detailed information.
        D.
SNC Definitions
Note: At this time, SNC definitions specific to different types of water systems have not yet been determined
for radionuclide regulation.  The following SNC definition, applicable to the radionuclide rule, has been
adopted and modified from an EPA Memorandum dated May 22, 1990.
Radionuclides Guidance
                          Appendix D-7
December 8, 2000

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        The SNC definition is composed of those violators which present the greatest risk to health and
which, therefore, are generally primary enforcement targets for all violators of the National Primary Drinking
Water Regulations (NPDWRs).


A Radiological SNC is a public water system which meets any of the following criteria:
        (a) Exceeds the unreasonable risk to health level identified for that contaminant. The unreasonable
               health level is 2 times the MCL.
        (b) Fails to monitor for or report the results of any of the currently regulated contaminants for two
               or more consecutive monitoring periods if they monitor more than once Qgjj&i, or failure to
               monitor or report results once if they monitor once a year or Has.


Refer to the SDWIS/FED Data Entry Instructions and the SD^S/FED^^^jjM Non-Compliance
Specifications for more detailed information.
December 8, 2000                           Appendix D-8                     Radionuclides Guidance

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IV.    SDWIS/FED Data Transmittal
The Data Transfer File (DTP) is the only format by which data can be entered into the SDWIS/FED data
base.

Each Data Transfer File record is 80 characters in length and has the following format:
Definition

Form ID

Qualifier 1

Qualifier 2

Qualifier 3

Action Code

Data Element Number

Data Value

Reserved for SDWIS/FED
        Positions

        1-2

        3-11

        12-18

        19-25

        26

        27-31

        32-71

        72-74
Batch Sequence Number                 75 - 80

* D = DELETE, I = INSERT, aodilrt = MODIFY
     Example

     Dl
               „-,;  -
      TREATMENT^)
:;;.  •£>,!, or M*

     Gnnnu
                                NNNNNN

FORM
ID




DATAADDRESS
QUALIFIERS
• „ ";
• .'il
niii? i niFAT •> fatAi t «

^cr.
CODE

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DATA
ELEM.
NUM.



DATA VALUE





N/A





Batch Sequence
Number



           3-11  12-18 19-25
26
      27-31
                   32-71
                                72-74
                  75-80
Radionuclides Guidance
        Appendix D-9
                December 8, 2000

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        The following table presents the SDWIS/FED violation record data elements for reporting
Radionuclides rule violations.
SDWIS/FED DTP Cl 100 - Violation Record Data Elements
DTP
Number
C101
C1101
C1103
C1105
C1107
C1109
C1123
/
Format
Character 9
Character 7
Character 4
Character 2
Date 8 (YYYYMMDD)
Date 8 (YYYYMMDD)
Decimal 6.9
Description
PWSID
Violation ID
Contaminant Code ;
\ •". !_ •:'.'."..««'i "'
. .•. •'». :•;;. '.. :
' - - '. ' . . ^ij •-:-',:•
^1
Violation Type GsdNI; "<
;-.v^-V'-.:: /
4 ...-"^i*1-.;,* , :.. **:•_ .,
/'.•-,., . '':•'- '•.•*!?:• :-*^'i ' Jf*Jf«-'* "^-
Monitjj^rg PeriodiBe^n:Cpit|||!;
MonJtoring Peflod End DaiiP^
-;/Vnalysis Result
L w;. : ".•'
Permissible Values
Must be includejkyvithin
SDWIS/FED Wpitory
fa j$*i? '
Cliaigj|i||S**l & 2 must be the
aware of J :
' 4000-Gross^^wlil'''-
401 0-CombineS®fium
:4006-Combined Uranium
p|Hgi-Beta Particles
*G2||eL^Average
0$WR
x»:v
iDate monitoring period begins
Date monitoring period ends
Required for MCL violations
only; Must be >= 0; Only one
significant digit should be
used

December 8, 2000
Appendix D-10
Radionuclides Guidance

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V.
Sources for Additional Information
       Additional technical  information on SDWIS/FED reporting  information can be obtained by
contacting Valerie Love-Smith of the Infrastructure Program, Drinking Water Protection Division, Office
of Ground Water and Drinking Water at (202)-260-5596, or from the following resources:

Revised Radionuclides Final Rule, December 7, 2000
Implementation Guidance for Radionuclides, December 2000
Revised Consolidated Summary of State Reporting Requirements for the Safe Drinking'Jf&er Information
System (SDWIS)
SDWIS/FED Data Entry Instructions
SDWIS/FED Online Data Dictionary                       :
SDWIS/FED Significant Non-Compliance Specifications, March 7, 1997
Radionuclides Guidance
                                Appendix D-11
December 8, 2000

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                             Appendix A
   Monitoring, Reporting, and Compliance Determination Examples
December 8, 2000
Appendix D-I2
Radionudides Guidance

-------

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.'..      •       ..V    : . ::      .;;'.      '•.     Example!:    A;..  .. ^    ••.:••  •  -i"     ;'•; .
A ground water (GW) system MD34590 serving 2,304 people in operation since 1989.  The system has
collected gross alpha samples for the 4 monitoring periods under the existing radionuclides rule (1988-1992,
1992-1996,1996-2000,2000-2004).  The system only has 1 entry point to the distribution system (EPTDS).
All gross alpha samples were between 5-9 pCi/L.  The radium-226 samples were all 2 pCi/1 or less and the
system was  in compliance with the  existing rule.  The system collected  a gross alpha, radium-226, and
radium-228 samples on June 3,2005 at the EPTDS.  Since gross alpha results were historically all below 15,
the system elects to use gross alpha as a surrogate for uranium.
Results:
Gross alpha = 7 ± 2 pCi/L                                             •  ^..
Radium-226 = 2± 1 pCi/L                                  •'': '       '; '^U
Radium-228 = 4 ± 2 pCi/L
Uranium = Not measured. The gross alpha value of 7 ± 2 is used as a sutfogate for m
[Although there is no significant variation in radium 226 levels historically, the combined radium results to
be considered for grandfathering exceed the combined radium MC£;:-lfie$ikresuIts should not be acceptable
for grandfathering and the system should be required to conduct 4 consecutive quarters of monitoring for
radium 226 and radium 228 in the initial monitoring period.]           llS? :•

Outcome:                                  . .''.     '-:!'; ''  ^;:-       ..->'
We are reporting and calculating compliance based on what the labteportS, we are not adding or subtracting
the ± values (for example, since the value reported by the lab forjgixjSSiaipha is 7 ± 2 pCi/L, the result used
for compliance calculations = 7 pCi/L). The combined radium 22157228 result sum equals 6 pCi/L. The
system would be required to take quarterly samples until 4 consecutive quarters are less than the MCL or the
State sets a different monitoring frequency as part of a formal compliance agreement. The gross alpha value
of 7 is between the gross alpha detection limit (3 pCi/L) and 1/2 MCL, and therefore the system reduces
monitoring for gross alpha to one^ample every six years {i.e., the next sample must be collected between
	and-..-.j*^,     ).  Using|gp>ss alpha as=asurrogate for uranium, the system assumes a value of 7
pCi/L. For simplicity of calculation, since the gross alpha result is less than 1/2 MCL for uranium, an
activity to mass~inatioof 1:1 is  assumed. '.•Therefore, a value of 7 ug/L is assumed for uranium, which is
between the urariiuiiiiiide^ection limiil^^^and'1/2 MCL, and the system is allowed to reduce monitoring for
uranium to one sample every six years (i.e., the next sample must be collected between	 and	


RsiH ,396/798
Initial
6/03/05
6pCi/T,
Quarter 2
9/10/05
7nri/T,
Quarter 3
12/12/05
nn sample
Quarter 4
3/31/06
4pri/T.
The State will report the following violations to SDWIS/FED:
1 -     M/R Violation (10/1/05 - 12/31/05)
2 -     (MCL Violation) (4/1/05 - 3/31/06)
        6 pCi/L + 7pCi/L + 4 pCi/L - 3 = 5.66 pCi/L, which rounds to 6 pC5/L
        [use one significant figure]
Radionuclides Guidance
Appendix D-13
December 8, 2000

-------
[Compliance is based on the running annual average as referenced in 40CFR141.26(c)(3)(iv)]
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MD5234590
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0655111
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IC1103
IC1105
IC1107
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1C 11 03 4
JPMOV '
•J«»
icntfr f i
. -friTT* .'
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1
Example 7
1
 GW system MD5234590 serving 1,510 people in operation since 1994. The system only has 1 entry
 point to the distribution system (EPTDS). The system has collected gross alpha samples for the 2
 compliance periods under the existing radionuclides rule (1992-1996, 1996-2000). The average gross
 alpha value for these periods was 4 pCi/L, so no radium 226 or radium 228 monitoring was required
 under the 1976 regulations. The State has informed the system that the revised rule will not be effective
 until December 7, 2003.  The State tells the system that if they collect EPTDS samples for gross alpha,
 radium-226, and radium-228, and uranium between June 2000 and December 7,2003 then they may be
 able to grandfather this data and not be subject to the initial quarterly monitoring requiren^nts.  The
 system collects samples for gross alpha, radium-226 and radium-228 on July 17. 2002^atmie EPTDS.
 Since all previous gross alpha results were less than 15 pCi/L, the system elects to use gross alpha as a
 surrogate for uranium.                                                  •.:='i-"i-'.
                                                                              Vr'jsjjjr
Results:
Gross alpha = 4 ± 1 pCi/L
Radium-226 = 1 ± 1 pCi/L                                                        '^\.
Radium-228 = 2 ± 1 pCi/L
                                                        ~ ~   ^ ^;
Uranium = Not measured. The gross alpha value of 4 ± 1 is used^&ninjgate for uranium.
 Outcome:                                                           <„•    '
 No violations to report to SDWIS/FED. The system is in compliance with the existing rule for the 2000-
 2004 compliance period (i.e., 1976 regulations). However, the ievised_radionuclides rule becomes
 effective December 7, 2003 and the system is grandfathering the data for the initial compliance period
 (2004-2007). The system would be on the following schedule forjcepeat monitoring:

        Gross alpha - result is greater Jhan a non-detect (ND) but less than Vz the MCL.  The
        system  must collect a sample once eveiy-6 years (i.e., the next sample is due between
        200$ltad2013).


        Rad«ml226?228 is greater tfjanM the MCL but less than the MCL. The system must
        collect a sampleonce eveiy 3 years (i.e., the next sample is due between 2008 and 2010).

        Uramtim"- Usfia^igross alpha as a surrogate for uranium, the system assumes a value of 4
        pCi/L.  For simplicity of calculation, since the gross alpha value is less than 1/2 MCL for
        uranium, an activity to nisass ratio of 1:1 is assumed and a value of 4ug/L is used for
        determining reduced monitoring for uranium.  Since 4 ug/L is between the detection
        level (DL) and 1/2 MCL, the system is allowed to reduce monitoring for uranium to one
        sample  every 6 years (i.e., the next sample is due between 2008 and 2013).
Radionuclides Guidance
                                        Appendix D-15
December 8, 2000

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 L	                           	       Rvampla 1                    :• '                   I
GW system MD5234590 serving 1,510 people in operation since 1994. The system only has 1 entry
point to the distribution system (EPTDS). The system has collected gross alpha and radium 226 samples
for the 2 compliance periods under the existing radionuclides rule (1992-1996, 1996-2000).  The State
has informed the system that the revised rule will not be effective until December 7,2003.  The State
tells the system that if they collect EPTDS samples for gross alpha, radium-226, radium-228, and
uranium between June 2000 and December 7, 2003 then they may be able to grandfather this data and not
be subject to the initial quarterly monitoring requirements.  The system collects samples for gross alpha,
radium-226,and radiurh-228, on July 17, 2002 at the EPTDS. Since all previous gross alpSa results were
less than 15 pCi/L, the system elects to use gross alpha as a surrogate for uranium.   ;
Results:                                                          ' ,
Gross alpha = 12 ± 1 piC/L
Radium-226 = 3 ± 1 piC/L
Radium-228 = 6 ± I piC/L
Uranium = Not measured. The gross alpha value of 12 ± 1  is/usedft&a surrogate for uran
Outcome:                                                    TJ
The system would be on the following schedule for repeat monitoring:   '  •"
       Gross alpha - result is greater than '/2 the MGL?b«tess:£han the MCEiand must collect a
       sample once every 3 years (next sample-^uire^beliioltt^OOS an<£2010).
       Radium-226/228 is greater than thf IftCL andtnust coIBt^irterly samples until the annual
       average is less than the MCL or tire State specifies a different monitoring frequency as part of a
       formal compliance agreement   <

       UrarJsum - Using gross aljiha as a surrflgjiBte fororanium, the system assumes a value of
       12-pGfiL. For simp^i^^calculatioi^ii&ce Aie gross alpha value is less than 1/2 MCL
       ibf ^iapUm, an acti4?i^|pt|iass ratio of 1 : 1 is assumed and a value of 12ug/L is used for
       detMiiiiaiii^ireduced nKjfilijraggifor uranium. Since 12 ug/L is between the DL and 1/2
       MCL, the system js allow'eii^lsedooe monitoring for uranium to one sample every 6
years

                                             2008 and 2013).
We are reporting and calculi ting|COmpliance based on what the lab reports (e.g. the number is the
numbjiF). Wearenotadd^^plbtractmgthe ± values (So for example gross alpha is 7 ± 2 pCi/L. We
woijld say the result = 7 pGi/L). The combined radium 226/228 result sum equals 9 pCi/L. The system
would be required to take quarterly samples until 4 consecutive quarters are less than the MCL, but
conapliance is based on the running annual average.
                     Initial
                         Quarter 2      Quarter 3     Quarter 4     Quarter 5
7/17/02     10/12/02      1/23/03

QnCi/T.     llnCi/T.
                                                           4/07/03
                                                                  7/14/03
December 8, 2000
                                 Appendix D-16
                                                    Radionuclides Guidance

-------
 The State will report the following violations to SDWIS/FED:
 1 -     Combined radium-226/228 MCL Violation (7/1/02 - 6/30/03)
 2 -     Combined radium-226/228 MCL Violation (10/1/02 - 9/30/03)
Columns
1-2
Dl
Dl
Dl
Dl
Dl
Dl
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Dl
Dl
ni
Columns
3-11
MD5234590
MD5234590
MD5234590
MD5234590
MD5234590
MD5234590
MD5234590
MD5234590
MD5234590
Mns-ndson
Columns
12-18
0255333
0255333
0255333
0255333
0255333
0355334
0355334
0355334
0355334
rm^^d
Columns
19-25



. ;>'

>. =:
... i';:;
• ••'•5
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Columns
26-31
IC1103
if|305 _;•••'


, IC1
::"-' IC1103 'vs|
IC1105
.':•••. IC1107
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^ . ,. . ~.~4i™1-,.
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32-71
: ' 4006
02
20020701
x 20030630 '
Ik, 10 '

*"'-:.'.• -'02
20021001
20030930
in
Radionuclides Guidance
Appendix D-17
December 8, 2000

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                                                                                            I
GW system MD5234590 serving 1,510 people in operation since 1994. The system only has 1 entry
point to the distribution system (EPTDS). The system has collected gross alpha and radium 226 samples
for the 2 compliance periods under the existing radionuclides rule (1992-1996,1996-2000). The State
has informed the system that the revised rule will not be effective until December 7, 2003. The State
tells the system that if they collect EPTDS samples for gross alpha, radium-226., radium-228, and
uranium between June 2000 and December 7,. 21, 2003 then they may be able to grandfather this data
and not be subject to the initial quarterly monitoring requirements. The system collects samples for gross
alpha, radium-226, radium-228, and uranium on July 17, 2002 at the EPTDS.
Results:
Measured Gross alpha = 41 ± 1 piC/L
Gross alpha (excluding uranium) = 41 - 29 = 12 pCi/L
Radium-226 = < 1 piC/L
Radium-228 = < 1 piC/L
Uranium = 32 ug/L and 29 ± 3 piC/L (mass  spec)
[The uranium result submitted by the system for grandfathering exceeds^te^CL. This result should not
be acceptable for grandfathering and the system should b&xequired to ?a|fidl^4
Outcome:                                : v
The system would be on the following schedule for repeat moni
        Gross alpha - For determinii^cbmpliance with the gross alpha MCL Uranium should be
       excluded from the calculatioffl|0-l"piC/L.|-59 piC/L = 12 piC/L). After subtracting out
       uranium, gross alpha is greiilir than l/z jlie MCL but less than the MCL. Therefore, the
       system  must collect a sample once evf^T:3 yeas {i.e., the next sample must be collected
       collecte^betweea^DOS
 Uranium - (MCE1
not effective until
                                      regulatory detection limit of 1 piC/L. The system
                                          ery 9 years (i.e., the next sample must be
                      and
                                  ) result is greater than the MCL but the uranium MCL is
                                r 7, 2003.  Legally, the system is in compliance with the
    »   current rule. Whdfc the revised rule becomes effective they will not be in violation of the
       rule, but the EPA is encouraging States to ensure these systems are in compliance by the
       effective date of the revised rule.  Since the uranium results submitted for grandfathering
;       exceed the MCL, they cannot be grandfathered, and the system must conduct 4
    ''"  consecutive quarters of monitoring for uranium during the initial compliance period.


The system is in compliance and has no violations to report to SDWIS/FED.
December 8, 2000
                                 Appendix D-18
Radionuclides Guidance


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                                           Kxatnnle
                                                                                            J
SW system serving 5,332 people in operation since 1995. The system has 2 entry points to the
distribution system (EPTDS). The system has collected gross alpha samples from a representative point
in the distribution system for the 2 compliance periods under the existing radionuclides rule (1992-1996,
1996-2000).  The gross alpha levels have exceeded the trigger of 5 pCi/L but the radium-226 levels have
all been less than 3 pCi/L, so the system has been in compliance with the existing (1976) rule. The State
has informed the system that the revised rule will not be effective until December 7, 2003. The State
tells the system that if they collect samples at both EPTDS for gross alpha, radium-226, radium-228, and
uranium between June 2000 and December 7, 2003 then they may be able to grandfather-this data and not
be subject to the initial quarterly monitoring requirements. The system collects samplesifor gross alpha,
radium-226, radium-228, and uranium on May 23, 2002 at each entry point tojthe distribution system
(identified as EP-1 and EP-2).
Results:
EP-1
Gross alpha = 10 ± I pCi/L
Radium-226 = 3 ± 1 pCi/L
Radium-228 = 6 ± 2 pCi/L
Uranium = ND                                                •;;
(The Agency will propose a detection limit for uranium tea:lBture rule
revised radionuclides final rule)
                                                          
-------
       Uranium - is less than the regulatory detection limit defined in 141.25(c) (Table B). The
       system must collect a sample once every 9 years (i.e., next sample must be collected
       between 2008 and 2016).

The system would be required to take quarterly samples at EP-1 until 4 consecutive quarters are less than
the MCL (or the State has specifies a different monitoring frequency as part of a formal compliance
agreement), but compliance is based on the running annual average.
                                 Quarter2     Quarters      Quarter44fr  Rafter5
                                                          •":.:      .. •':-'••,•••• •*?».
               Initial


               5/23/02    8/12/02       11/19/03     2/07/03., *?, 3

lad 226/228    9 pCi/I     17pri/T.	17pf.i/I;     1
The State will report the following violations to SDWIS/FEB: ; ^
1 -     Combined radium-226/228 MCL Violation reported
2 -     Combined radium-226/228 MCL Violation reported for
Columns
1-2
DI
DI
Dl
Dl ,
Bl ./.;.£
Dl X '" •?•
Dl

Dl
1)1
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3-11
MD56 12950
MD56 12950
MD56 12950
MD5612950X
MD5612950;?!
"'mWNC^S | OQ^fl "•'*••'
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iBolumns
^.r 26-31
r 1C 11 03
IC1105
ICI107
IC1109
IC1123
IC1103
IC1105

IC1107
IC1109
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Columns
32-71
4010
02
20020401
20030331
11
4010
02

20020731
20030630
19
December 8, 2000
                                  Appendix D-20
Radionuclides Guidance

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L
                                           Kxamtile
             J
GW system serving 3,862 people in operation since 1995. The system has 2 entry points to the
distribution system (EPTDS). The system has collected gross alpha samples from a representative point
in the distribution system for the 3 compliance periods under the existing (1976) radionuclides rule
(1992-1996, 1996-2000, 2000-2004). The gross alpha levels have exceeded the trigger of 5 pCi/L but the
radium-226 levels have all been less than 3 pCi/L, so the system has been in compliance with the existing
rule. The system does not collect any radium-228 samples prior to the effective date of the revised
radionuclides rule. The State has made a written finding that the samples collected from the distribution
system during the 2000-2004 compliance period under the existing rule are representative.^ both entry
points and allows the system to grandfather the gross alpha and radium-226 data.  The/system decides not
to use gross alpha as a surrogate for uranium. The system collects quarterly.S^|ij|e^|f6r radium-228 and
uranium on June 1, 2005 at each entry point to the distribution system (identij^is^EP-1 and EP-2).
[Wouldn't the system be required to collect four quarters for uranium and radi)|nii2JS|Juring initial     •
monitoring? We should clarify this.]                                     •    VV1~:
 Results:                                                                     '•'.'.'
 Representative point in distribution system (grandfathered data from.2flOQ-2004 period):
 Gross alpha = 10 ± 1 pCi/L                                    :V;.V ;  ,
 Radium-226 = 3 ± 1 pCi/L                                        V'-iii,-,

 Samples collected to comply with revised radionuclides rule:
 EP-1                                                                            EP-2
 Radium-228 = 6 ± 2 pCi/L                                  Radhim-228 = 4 ± 1 pCi/L
 Uranium = ND                                                   Uranium = ND
 (The Agency will propose a detection limit for uranium in a future rule before the effective date of the
 revised radionuclides final rule)

 Outcome:                      • ,
 The system would be on the following schedule for repeat monitoring:
 EP-I       •; ..             ;:•"'• r
        Gross aloha-result (10 pCi/£) is greater than 1A the MCL but less than the MCL. The
        system itt^^lifej^;SampleiMice every 3 years (i.e., the next sample must be collected
        between
       Radium-226/228 -isgreffllerthan the MCL.  The system must collect quarterly samples.
       The radium-226 value of 3 pCi/L from the grandfathered data is added to the radium-228
       value of 6 pCi/L (for a combined value of 9 pCi/L)
       Uranium - is less than the regulator)' detection limit defined in 141.25(c) (Table B). The
       system must collect a sample once every 9 years (i.e., the next sample must be collected
       between 2008 and 2016).

       Gross alpha - result (10 pCi/L) is greater than V2 the MCL but less than the MCL.  The
       system must collect a sample once every 3 years (i.e., the next sample must be collected
       between 2008 and 2010).
       Radium-226/228 - result is greater than the MCL.  The system must collect quarterly
       samples. The radium-226 value of 3 pCi/L from the grandfathered data is added to the
       radium-228  value of 4 pCi/L (for a combined value of 7 pCi/L)
Radionuclides Guidance
                                        Appendix D-21
December 8, 2000

-------
       Uranium - is less than the regulatory detection limit defined in 141.25(c) (Table B).  The
       system must collect a sample once every 9 years (i.e., the next sample must be collected
       between 2008 and 2016).

The system would be required to take quarterly samples at EP-1 and EP-2 until 4 consecutive quarters are
less than the MCL or until the State specifies a different schedule as part of a formal compliance
agreement. But compliance is based on the running annual average. The system is required to take
quarterly samples at EP-1 and EP-2 for radium-226 and radium-228:
       P-2

      RaH 926/228
                     Initial
           Quarter 2
             Quarter 3      Quarter 4/ys;   QuaHer 5
              ^            ^      ff*«'C"'. '  >•' .,
                                  £M&
       P-l           6/01/05     9/12/05

      gad22.fi/228    Q pf^/l
                         12/19/05,'    3/07/06  >

                         1 1 pri/T.      8
                     Initial
6/01/05
Quarter 2


9/12/05

4 nCi/T .
                         Quarter & -^terter 4     Quarter 5
12/19/05
6/16/06

4pf!i/T.
The State would report the following violations to SDWIS/FED:'.' ^:;:-"
1 -     Combined radium-226/228 M<|L Violatipii^/01/05-3/31/06) reported for the system
2-     Combined radium-226/228.;f$!§L Viola^p (7/01 /OS ^6/30/06) reported for the system
NOTE: Even though both entry points (EPtfSHid EP-2) had MCL violations, the State only has to
report tttat^ejfystem had ay|i|jiioD. The State should report the highest concentration in the
concentratWBifleldior the systegaefiilthis case EP-1 had the highest MCL quarterly average of 9
pCi/L for the period4/OJ/05 to3lliifllS«ad the highest MCL quarterly average of 10 pCi/L for the
period of 7/1/05 to 6/30/06,
December 8, 2000
                   Appendix D-22
                                        Radiomiclides Guidance

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Columns
1-2
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Dl
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MD56 12950
MD56 12950
MD56 12950
MD56 12950
MD5612950
MD5612950
MD5612950
MD5612950
MD5612950
vmv5i2<)sn
Columns
12-18
0666661
0666661
0666661
0666661
0666661
0666661
0666661
0666661
0666661
0666661
Columns
19-25









•-•.. ;•„ __.-;•
Columns
26-31
IC1103
IC1105
IC1107
IC1109
IC1123
IC1IG3 ;
IC1105 „
icHo? ;4|
-/IC1109 $
mm
Columns
32-71
4010
02
20050401
20060331
9
4010
02
IN 20050701 •'
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3$5686W3Cr
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Radionuclides Guidance
Appendix D-23
December 8, 2000

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                                                       <•;•  rKV.•£-»_.-'
                             This page has been intentionally Jeffi
December 8, 2000
Appendix D-24
Radionudides Guidance

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Appendix
                 es
        on Audit Law

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                             This page has been intentionally
December 8, 2000
Appendix E-2
Radionuclides Guidance

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                        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, O.C. 20460
                                      FEB  14  1997
        MEMORA.MPUM

        SUBJECT:   Statement of Principles
                     Effect of State Audit Immunity/Privilege Laws
                       OR Enforcement Authority for Federal Programs
TO;
FROM:
                     Regional Administrators
                                 IT, OECA
                     Steven A, Hi
                     Assistant

                     Robert Perciasepe
                     Assistant Administrati

                     Mary Nichols
                     Assistant

                     Timothy Fields
                     Acting Assistant
               Under federal law, states must have nrirqna*r authority to enforce the requirements of any
         federal programs they are authorized to administer. Some state audit immunity/privilege laws
         place restrictions on the ability of states to obtain penalties and injuncthre relief for violations of
         federal program requirements, or to obtain information that may be needed to determine
         compliance status. This statement of principles reflects EPA's orientation to approving new state
         programs or program modifications in the face of sate audit laws mat restrict state enforcement
         and information gathering authority. While such state laws may raise questions about other
         federal program requirements, this statement is United to the question of when enforcement and
         information gathering authority may be considered adequate for the purpose of approving or
         delegating programs in states with audit privilege or immunity laws.
Radionitclides Guidance
                                      Appendix E-3
December 8, 2000

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       L Audit Immunity Laws

             Federal law and regulation requires states to have authority to obtain injunctive relief; sad
       civil and criminal penalties for any violation of program requirements. In determining whether
       to authorize or approve a program or program modification in a state -with an audit immunity
       law, EPA must consider whether the state's enforcement authority meets federal program
       requirements. To maintain such authority while at the same time providing incentives for sclf-
       policing in appropriate circumstances, states should rely on policies rather than enact statutory
       immunities for any violations. However, in detennining whether these requirements are met in
       states with laws pertaining to voluntary auditing, EPA will be particularly concerned, among
       other factors, with whether the state has the ability to:

              1) Obtain immediate and complete injunctive relief;

              2) Recover civil penalties for

                    i) significant economic benefit;

                    ii) repeat violations and violations of judicial or administrative orders;
      v
                    iii) serious harm;

                    iv) activities that may present imminent & substantial
              3) Obtain criminal noes/sanctions for wilful and knowing violations of federal law, and
              in addition for violations that result from gross negligence under the Clean Water Act

       The presumption is that each of these authorities must be present at a mtnitmm before the state's
       enforcement authority may be considered adequate.  However, other factors hi the statute may
       eliminate or so aairow the scope of penalty immunity to the point where EPA's concerns are
       met For example:

              1) The immunity provided by the statute may be limited to minor violations and contain
              other restrictions that sharply limit its applicability to federal programs.

              2) The statute may include explicit provisions that make h inapplicable to federal
              programs.

        n. Audit Prrnlege Laws

               Adequate civil and criminal enforcement authority means that the state must have the
        ability to obtain information needed to identity noncompliance and criminal conduct.  In
December 8, 2000                             Appendix E-4                        Radionuclides Guidance

-------
        determining whether to authorize or approve a program or program modification is a state with
        an audit privilege law, EPA expects the state to:

               1) retain information gathering authority it is required to have under the specific,
               requirements of regulations governing authorized or delegated programs;

               2) avoid making the privilege applicable to criminal investigations, grand jury
               proceedings, and prosecutions, or exempt evidence of criminal conduct from the scope of
               privilege;

               3) preserve the right of the public to obtain information about noncompliance, report
               violations and bring enforcement actions for violations of federal environmental law.  For
               example, sanctions for whistleblowers or state laws that prevent citizens from obtaining
               information about noncompliance to which they are entitled under federal law appear to
               be inconsistent with this requirement

        HI. Applicability of Principles

               It is important for EPA to clearly communicate its position to states and to interpret the
        requirements for enforcement authority consistently. Accordingly, these principles will be
        applied in reviewing whether enforcement authority is adequate under the following programs:

                1) National Pollutant Discharge Elimination System (NPDES), Pretrsatment and
                Wetlands programs under the Clean Water Act;

                2) Public Water Supply Systems and Underground Injection Control programs under the
                Safe Drinking Water Act;

                3) Hazardous Waste (Subtitle  C) and Underground Storage Tank (Subtitle I) programs
                under the Resource Conservation Recovery Act;

                4) Title V, Hew Source Performance 'Standards, National Emission Standards for
                Hazardous Air Pollutants, and New Source Review Programs under the Clean Air Act

         These principles are subject to three important qualifications:

                1) While these principles will be consistently applied in reviewing state enforcement
                authority under federal programs, state laws vary in their detail. It will be important to
                scrutinize the provisions of such statutes closely in  determining whether enforcement
                authority is provided.

                2) Many provisions of state law may be ambiguous, and It will generally be important to
                obtain an opinion from the state Attorney General regarding the meaning of the state law
Radionuclides Guidance
Appendix E-5
December 8, 2000

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             and the effect of die stale1 s law on its enforcement authority as it is outlined in these
             principles. Depending on its conclusions, EPA may determine that the Attorney
             General's opinion is sufficient to establish that the state has the required enforcement
             authority.

             3) These principles arc broadly applicable to the requirements for penalty and information.
             gathering authority for each of the programs cited above. To the extent that different or
             more specific requirements for enforcement authority may be found in federal law or
             regulations, EPA will take these into account in conducting its review of state programs.
             In addition, this memorandum does not address other issues that could be raised by state
             audit laws, such as the scope of public participation or the availability to the public of
             information within die state's possession.           .          —      -   .      •

       IV. Next Steps

             Regional offices.shodd, in consultation with OECA and national program offices,
       develop a state-by-state plan to work with states to remedy any problems identified pursuant to
       application of these principles. As a first step, regions should contact state attorneys general for
       an opinion regarding the effect of any audit privilege or immunity kw on enforcement authority
       as discussed in these principles.
December 8, 2000                              Appendix E-6                        Radionuchdes Guidance

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Appendix F
Rule Presentations

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              Radionuclides
     Notice of Data Availability

         NRWA In-Service Training
                 July 18,2000

                 Ed Thomas
             Office of Ground Water
               and Drinking Water
 Overview

   Purpose
   History
   Monitoring requirements
   Treatment
   Costs
 Purpose of Regulating
     Health Effects (eachsrad targets specific organs)
       known carcinogen-predominantly bone cancer
         Others include ovaries, testes, breast, thyroid, liver, etc.
         Children pa»Bai!arly sensitive to carcinogenic effects
     .  organ and cet! toxicity
         kidney, fiver, anemia
December 8, 2000
Appendix F-2
Radionuclides Guidance

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 Purpose  of Regulating (Cont.)

   Naturally occurring Sources
      Uranium:  granitic formations
      Radium: geologically predominant in upper mid-west,
      western mountains, piedmont, coastal plain
      sediments
      K-40: isotopes of naturally occurring potassium.

   Man made Sources
      Uranium:  Mining and nuclear weapon development
      Beta emitters: Nuclear power plants, hospitals,
      military
                                /  .
 Regulatory History


    1976 IPDWS - Current rule effective for 23 yea?|| ^
      radium-226 and radium-228                  '• --<-,;
                                              .a.'.
      gross alpha                     ::„;      jJ  '
      man-made beta/photon emitters              v
    1986 SDWA Amendments
      Made 1976 IPDWS a NPDWS  ^
      Required EPA to revise existingjole and regdate Uranium
      and Radon by 1989       ;...''        . •,., =s.sjil
 Regulatory
(Cont.)
        Published PR lei meet court order (no FR)
 ,; 4996 SDWA Amendments - Required withdrawal
   of 1991 PR radon portion
 I 1996 revised Court Order
                 ium
   f Update existing rule
   4/21/2000 - NODA
   11/21/2000 -  Revised Rads FR
Radionuclides Guidance
        Appendix F-3
December 8, 2000

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 MCL's

   Current Limits
      Gross alpha (including Ra-226) = 15 piC/L
      Radium 226/228 (combined) = 5 piC/L
      Beta/photon screen = 15 piC/L and 50 piC/L
      Beta/photon MCL's = 4 mrem total exposure

   2000 NODA does not change MCL's or beta
   screening triggers
      Uranium MCL = 20, 40, or 80 (piC/L and ug/l)
   Applicability

   All CWS (GW and SW)

   NTNCWS (Options)
     All NTCWS must comply
     Targeted NTNCWS must comply
     Targeted NTNCWS monitor (MCL not enforceable)
     Issue guidance
     Exclude NTNCWS
 Alpha, Rad 226/228,  and U
 Monitoring
 I Initial Monitoring
    ?  4 qtrs. (most systems GF data but...)
        Current rule: GA >5 -> Rad-226 >3 -+ Rad-228
        New regulation for Uranium (GA may be used as surrogate)
        Requires EPTDS samples
December 8, 2000
Appendix F-4
Radionuclides Guidance

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 Alpha, Rad 226/228, and U
 Monitoring (Cont.)

   Reduced Monitoring (SMF)
     Average < ND =>       1 sample/9 years
     ND< Average <50%=>   1 sample/6 years
     I MCL< Average MCL =>              Quarterly samples
 Grandfathering off Data

   Use of GF Data for initial monitoring
     Systems with 1 EPTDS may use distributklNystenV
     data from last compliance period
     Systems with existing EPTDS sample^from last ••.'••
     compliance period
     Systems may use distribution system sample if State
     gives written approval      ^      .•&
   Others?                 J          r
                                    '"
 Beta/Photon
ring
   State designated as vulnerable
  ->f Quarterly samples for Gross Beta
   ! Annual samples for Tritium and Strontium
   :;!g|f Gross Betr>30 piC/L => Speciate sample

   Systems using contaminated source
     Quarterly samples for Gross Beta and Iodine
     Annual samples for Tritium and Strontium
     If Gross Beta >15 piC/L =s> Speciate sample
Radionuclides Guidance
       Appendix F-5
December 8, 2000

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 Small System Compliance Tech.


   25-500 persons - Ion exchange, POU, RO, POU
   RO, lime softening, green sand filtration, co-
   precipitation, electrodialysis reversal,

   500-10,000 persons - add activated alumina and
   enhanced coagulation/filtration
   "Small Systems Compliance Technology List"
   http://www.epa.gov/OGWDW/standard/tretech.html
Wa
ter System Impacts
Total Number of. Systems out of
compliance .„;; ;
#Persons
Served
25-500
501-3300
3301-10000
Radium
(#)
250
120
Alpha Uranium
(#) (#)
170 300-760
120 0-60

Annual Household Costs
Annual Total Increased Cost
Per Household
Served '
25-500
501-3300
3301-10000
Raefcim Alpha Uranium
-•<$) ($) ($)
214 - 1,465 214 - 560 172 -1,465
49-831 49-831 38-831
37-4,696 50-493 24-4,6%
Beta's
ft)
172-1,465
38-831
24-493
December 8, 2000
Appendix F-6
Radionuclides Guidance

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Appendix G
Rule Language

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                             This page has been intentionally left blank.
December 8, 2000
Appendix G-2
Radiomtdides Guidance

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List of Subjects
40CFRPart9
        Reporting and recordkeeping requirements.
40 CFR Part 141   •
        Environmental protection, Chemicals, Indian-lands, Incorporation by reference,
Intergovernmental relations, Radiation protection, Reporting and recordkeeping requirements, Water
supply.
40 CFR Part 142
        Environmental protection, Administrative practice and procedure, Chemicals. iniHian-lands,
Intergovernmental relations, Radiation protection, Reporting and recordkeepingtequiirements, Water
supply.
Dated:
Carol M. Browner,
Administrator
Radionuclides Guidance
Appendix G-3
December 8, 2000

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        For reasons set out in the preamble, 40 CFR Parts 9, 141 and 142 are amended as follows:
1. The authority citation for part 9 continues to read as follows:
       Authority: 7 U.S.C. 135 et seq., 136-136y; 15 U.S.C. 2001,2003, 2005, 2006, 2601-2671; 21
U.S.C. 331j, 346a, 348; 31  U.S.C. 9701; 33 U.S.C. 1251 et seq., 1311, 1313d, 1314,1318, 1321, 1326
1330,1324, 1344, 1345 (d) and (e), 1361; E.G. 11735, 38 FR 21243, 3 CFR, 1971-1975 Comp. p. 973;
42 U.S.C. 241,242b, 243, 246, 300f, 300g, 300g-l, 300g-2, 300g-3, 300g-4, 300g-5, 300g-6,300J-1,
300J-2, 300J-3, 300J-4, 300J-9, 1857 et seq., 69016992k, 7401-7671q, 7542, 9601-9657,11023, 11048.
2. In § 9.1 the table is amended by:
(a)    removing entries "141.25-141.30" and adding new entriesfor
       141.26 (a) and (b), and 141.27-141.30               ;-;,>:
(b)    removing entries 142. 14(a)-(d)(7) and adding 142.14-(a)-(d)(3), 14^11 (t
       and 142.14(dX6)-(7)                           ,
(c)    removing entries 142.15(c)(5)-(d) and adding 142.1^5(cX^|2.15(c)(6) and (
       142.15(d)                                        ';"•&•-
§ 9.1 OMB approvals under the Paperwork Reduction Act.    -\ iiiSiKd,.
*****
       40 CFR citation
*****
 National Primary Drinking Water Regulations
*****
141.25(a)-(e)
                                  .. ...... 2040-0228
                                      OMB control
                                      No.
*****
                   National Primary Drinking Water Regulations Implementation
*,-*;#--« *
                                       2040-0090
I42.14(idX4)tnd (5)	2040-0228
142.14CdX6)-(7)	2040-0090
142.14(d)(8)-(ll)	2040-0210
142.14(e)	2040-0090
142.14(f)	2040-0209
142.14(g)	2040-0090
December 8, 2000
Appendix G-4
Radionuclides Guidance

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 142.15(a)	2040-0090,
                                       2040-0209
 142.15(bXc)(3)	2040-0090
 142.15(c)(4)	2040-0210
 142.15(c)(5)	2040-0090
 142.15(c)(6)and(7)	2040-0228
 142.15(d)	2040-0090
*****
Part 141—National Primary Drinking Water Regulations       ,.?
1. The authority citation for part 141 continues to read as follows:
       Authority: 42 U.S.C. 300f, 300g-l, 300g-2, 300g-3,300g-4, 30Qg-5, 300
       300J-11.
                                                , and
Subpart B-[Amended]

2. Sections 141.15 and 141.16 are removed.                           ;!;:.'
§§ 141.15 and 141.16 [remove]                                    C*l
3. Section 141.25 is amended by:                                    v
a. Revising paragraph (a) introductory text (the table remains imcttanged),
b. Revising paragraph (c)( 1) and adding a new table in (c)( 1),    ^ .
c. Revising paragraph (c)(2) and redesignating the table in (c)(2).
c. Revising paragraph (d).
The revision and addition read as toltows:
§141.25 Analytical metho
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(2) To determine compliance with §141.66 (d) the detection limits shall not exceed the concentrations
listed in Table C.
Table C-Detection Limits for Man-Made Beta Particle and Photon Emitters


(d) To judge compliance with the maximum contaminant levels listed in §141.66, averages of data shall
be used and shall be rounded to the same number of significant figures as the maximum contaminant
level for the substance in question.
*****
                                                                               immunity
Subpart C-[ Amended]
4. Section 141.26 is revised including the heading to read as follows:
§ 141.26 Monitoring frequency and compliance requirementPTor radio:
water systems
(a)  Monitoring and compliance requirements for gross aloha particlfiactivitv, n
228, and uranium,                                     '  1.  .  ; -
(1)  Community water systems (CWSs) must conduct initial tnoai|oimg to determine compliance with §
141.66 (b), (c) and (e) by December 31, 2007. For the purposes||i^p^ring for gross alpha particle
activity, radium-226, radium-228, uranium, and beta partickand'1p«&f^g^gactivity in drinking water,
"detection limit" is defined as in § 141.25(c).            v        x
(i) Applicability and sampling location for existing cottmuniSy water sy^^B»'Sources.  All existing
CWSs using ground water, surface water or systore agi^tiOih-ground andlpface water (for the

purpose of this section hereafter referred to as,«ystems) raus&saoiple.at evicry entry point to the
distribution system that is representative of ail sources Being^iise^feipfter called a sampling point)
under normal operating conditions. The system must take each sample at the same sampling point unless
conditions make another sampling poiat more representative of each source or the State has designated a
distribution system location, in accor$a»ee with paragraph (a)(2)(ii)(C) of this section.
(ii) Applicability and sampling lo^pon for nej^i»mmunit;S!f water systems or sources. All new CWSs or
CWSs that use a new source of waler must be§ji|lo conduct initial monitoring for the new source within
the first quartier»after initiating tt||fpf the sourwipGWSs'must conduct more frequent monitoring when
ordered by tfte State 
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 (C)    To satisfy initial monitoring requirements, a community water system with appropriate historical
        data for a representative point in the distribution system may use the monitoring data from the
        last compliance monitoring period that began between June 2000 and [INSERT DATE 3
        YEARS AFTER  PUBLICATION IN THE FEDERAL REGISTER], provided that the State
        finds that the historical data satisfactorily demonstrate that each entry point to the distribution
        system is expected to be in compliance based upon the  historical data and reasonable
        assumptions about the variability of contaminant levels between entry points. The State must
        make a written finding indicating how the data conforms to the these requirements.
 (iii) For gross alpha particle activity, uranium, radium-226 and radium-228 monitoring, the State may
 waive the final two quarters of initial monitoring for a sampling point if the results of thfcsamples from
 the previous two quarters are below the detection  limit.
 (iv) If the average of the initial  monitoring results for a sampling point is abo1|tetli«!'MCL, the system
 must collect and analyze quarterly samples at that sampling point until the system has results from four
 consecutive quarters that are at or below the MCL, unless the system enters^oianofliwiichedule as part
 of a formal compliance agreement with the State.                     .  ,J.  "      ,  " * ,^t>J ,
 (3) Reduced monitoring:  States may allow community watervsysterniF*6 reduce the fittp|tency of
 monitoring from once every three years to once every six or oine^eacs at each sampling pojSlf based on
 the following criteria.                                       -:;:15.
                                                           ' , • a*1,'5'*'"
 (i) If the average of the initial monitoring results for each ccm*am|ig^i.e^,,gross alpha particle activity,
 uranium, radium-226, or radium-228) is below the detection limit s|HSScd4ii'§ 141.25 (c)(l) (Table B),
 the system must collect and analyze for that contaminant using at least oneiaihpl& at that sampling point
 every nine years.
 (ii) For gross alpha particle activity and uranium, if the : average :<&the initial monitoring results for each
 contaminant is at  or above the detection limitbut at or below 14 thli^ejL the system must collect and
                                        • ' ''        • •   \   ••••v.-.-Kilkw.,:-."     J
 analyze for that contaminant using at least one sample at that samjpHiijfppoint every six years. For
 combined radium-226 and radium-228, the analytical results musTBe combined.  If the average of the
 combined initial monitoring results forradium-226 and radium-228 is  at or above the detection limit but
 at or below V2 the MCL, the system4imist collect and analyze for that contaminant using at least one
 sample at that sampling point every six years.
 (iii) For gross alpha particle activity and uranium, if the average of the initial monitoring results for each
 contaminantJsaijoye V* th«Mii||||$4t or below-theMCL, the system must collect and analyze at least
 one sample at that;»aripling pcifi^iryithree years.  For combined radium-226 and radium-228, the
 analytical results must be combineS^Jf the^average of the combined initial monitoring results for radium-
 226 and radium-228 is above !/2 the  MCL but at or below the-MCL, the system must collect and analyze
 at least one sample attJ^sampling point every three years.
 (iv) Systems must use thfe samples collected during the reduced monitoring period to determine the
 monitoring frequency for subsequent monitoring periods (e.g.,  if a system's sampling point is on a nine
 year.monitoring period, and the sample result is above 1A MCL, then the next monitoring period for that
 sampling point is  three years).
 (v) If a system has a monitoring result that exceeds the MCL while on reduced monitoring, the system
 must collect and analyze quarterly samples at that sampling point until the system has results from four
 consecutive quarters that are below  the MCL, unless the system enters  into another schedule as part of a
 formal compliance agreement with the State.
 (4) Compositing: To fulfill quarterly monitoring requirements for gross alpha particle activity, radium-
 226, radium-228,  or uranium,  a system may composite up to four consecutive quarterly samples from a
 single entry point  if analysis is done within a year of the first sample.  States will treat analytical results
 from the  composited as the average analytical result to determine compliance with the MCLs and the
 future monitoring frequency.  If the analytical result from the composited sample is greater than Vz MCL,
the State may direct the system to take additional quarterly samples before allowing the system to sample
under a reduced monitoring schedule.
Radionudides Guidance
Appendix G-7
December 8, 2000

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(5) A gross alpha particle activity measurement may be substituted for the required radium-226
measurement provided that the measured gross alpha particle activity does not exceed 5 pCi/1. A gross
alpha particle activity measurement may be substituted for the required uranium measurement provided
that the measured gross alpha particle activity does not exceed  15 pCi/1. The gross alpha measurement
shall have a confidence interval of 95% (1.65o, where o is the standard deviation of the net counting rate
of the sample) for radium-226 and uranium.  When a system uses a gross alpha particle activity
measurement in lieu of a radium-226
and/or uranium measurement, the gross alpha particle activity analytical result will be used to determine
the future monitoring frequency for radium-226 and/or uranium. If the gross alpha particle activity result
is less than detection, Vz the detection  limit will be used to determine compliance and th^piture
monitoring frequency.
(b) Monitoring and compliance requirements for beta particle and phi
To determine compliance with the maximum contaminant levefa|rf^l41.66l^^c«vSstojparticle and
photon radioactivity, a system must monitor at a frequency as follows:    i
(1) Community water systems (both surface and ground wajter) designafed'by the
must sample for beta particle and photon radioactivity. Systenisjnus^cbllect quarterly^i||pis?ft>r beta
emitters and annual samples for tritium and strontium-90 at «aelt|||iy, point to the distribution system
(hereafter called a sampling point), beginning within one quartes^|^^iejng notified by the State.
                                                                        reviews and either
Systems already designated by the State must continue to sample
reaffirms or removes the designation.
(i) If the gross beta particle activity minus the naturally occurring potas§nnip40 beta particle activity at a
sampling point has a running annual average (comj>iit^j|aart|^y) less thattjoeequal to 50 pCi/L
(screening level), the State may reduce the frequency ofTiKa^y||^: at that sampling point to once every
3 years. Systems must collect all samples reqporred in paragrj^|ji||rO'tsthis section during the reduced
monitoring period.                      •~/               •'•*•:>%•'•'•-.'
                                      •• •          •        :  '£^-f
(ii) For systems in the vicinity of a nupfev facility, the State may allow the CWS to utilize
environmental surveillance data coll^c|Bd-by the abclear facility in lieu of monitoring at the system's
entry points), where the State deteimifnes if sudjlldata is applicable to a particular water system. In the
event that there is a release from a nuclear facOSty, systems which are using surveillance data must begin
monitoring at the community water system's efibypoint(s) in accordance with paragraph (b)(l).
                     sys
                      efflu
(2)
waters
radioactivity. S&ems must colle
samples for tritium
sampling
                          itium-'
                               one
designated by the State
continue to sample until
      :ace arid-ground water) designated by the State as utilizing
      .clear facilities must sample for beta particle and photon
          samples for beta emitters and iodine-131 and annual
         'entry point to the distribution system (hereafter called a
           after being notified by the State. Systems already
iUsing waters contaminated by effluents from nuclear facilities must
 sviews and either reaffirms or removes the designation.
(i) Quarterly monitoring for g«ws beta particle activity shall be based on the analysis of monthly
samples or the analysis ofa composite of three monthly samples. The former is recommended.
(ii): For iodine-131, a composite of five consecutive daily samples shall be analyzed once each quarter.
As ordered by the State, more frequent monitoring shall be conducted when iodine-131 is identified in
the ftoishecLwatet.
(iii)  j^miualtBOnitoring for strontium-90 and tritium shall be conducted by means of the analysis of a
composite of four consecutive quarterly samples or analysis of four quarterly samples. The latter
procedure is recommended.
(iv)  If the gross beta particle activity beta minus the naturally occurring potassium-40 beta particle
activity at a sampling point has a running annual average (computed quarterly) less than or equal to 15
pCi/L, the State may reduce the frequency of monitoring  at that sampling point to every 3 years. Systems
December 8, 2000
                                          Appendix G-8
                                           Radionuclides Guidance

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must collect all samples required in paragraph (b)(2) of this section during the reduced monitoring
period.
(v) For systems in the vicinity of a nuclear facility, the State may allow the CWS to utilize
environmental surveillance data collected by the nuclear facility in lieu of monitoring at the system's
entry point(s), where the State determines if such data is applicable to a particular water system.  In the
event that there is a release from a nuclear facility, systems which are using surveillance data must begin
monitoring at the community water system's entry point(s) in accordance with paragraph (b)(2).
(3) Community water systems designated by the State to monitor for beta particle and photon
radioactivity can not apply to the State for a waiver from the monitoring frequencies specified in
paragraph (b)( 1 ) or (b)(2) of this section.                                           V
(4) Community water systems may analyze for naturally occurring potassiuasj^Jb^'particle activity
from the same or equivalent sample used for the gross beta partiQle^ctivityapfllysIS; , Systems are
allowed to subtract the potassium-40 beta particle activity value ftem the totaiigrd^s!be"ta particle activity
value to determine if the screening level is exceeded. The potassium-40 beta parthSesletlVity must be
calculated by multiplying elemental potassium concentrations (in mg/L)foy a
(5) If the gross beta particle activity minus the naturally occuma£j>otassium-4Q
exceeds the screening level, an analysis of the sample must be performed to identify the major
radioactive constituents present in the sample and the appropriatedoses must be calculated and summed
to determine compliance with §141.66(d)(l), using (d)(2). DQSes-:jjiittSt;alsp,be calculated and combined
for measured levels of tritium and strontium to determine compliance.' ••;  •• •;•
(6) Systems must monitor monthly at the sampling poiot|s)"which exceed!tii$dB£&imurn contaminant
level in § 141 .66(d) beginning the month after the exoesfi^ijeiccurs. SystaB&rhust continue monthly
monitoring until the system has established, by 4 ro11mg««i^%i6:£3 montWy samples, that the MCL is
being met. Systems who establish that the MCL is being:imta|inlB|lprettnil4o quarterly monitoring until
they meet the requirements set forth in paragraph (b)(lXii) or (b)^^):6f this section.
(c) General monitoring and compliance requirements for radionuclides.
(1) The State may require more frequent-monitoring than specified in paragraphs (a) and (b) of this
section, or may require confirmation samples at its discretion. The results of the initial and confirmation
samples will be averaged for use in compliance determinations.
(2) Each public water systems shalteionitor at the time designated by the State during each compliance
period.      .- ,,^^, .,       • .   '..:''«,",..'
(3) Complianceft&xnpjiance wtiti|J4'I.66 (b) through (e) will be determined based on the analytical
result(s) obtained ^«|E:h;sampling^poi|iL If one sampling point is in violation of an MCL, the system is
in vio lation  Of thtf;ll(i^li3i;;;v
(i) For systems monitbtiii^aioie'Jhan once per year, compliance with the MCL is determined by a
running annual average at each sampling point. If the average of any sampling point is greater than the
MCL, then the system is out of compliance with the MCL.
(ii) For systems monitoringTnore than once per year, if any sample result will cause the running average
to exceed the MCL at any sample point, the system is out of compliance with the MCL immediately.
(Hi) Systems must include all samples taken and analyzed under the provisions of this section in
determining compliance, even if that number is greater than the minimum required.
(iv) If a system does not collect all required samples when compliance is based on a running annual
average of quarterly samples, compliance will be based on the running average of the samples collected.
(v) If a sample result is less than the detection limit, zero will be used to calculate the annual average,
unless a gross alpha particle activity is being used in lieu of radium-226 and/or uranium.  If the gross
alpha particle activity result is less than detection, V4 the detection limit will be used to calculate the
annual average.
(4) States have the discretion to delete results of obvious sampling or analytic errors.
Radionuclides Guidance
Appendix G-9
December 8, 2000

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 (5) If the MCL for radioactivity set forth in § 141.66 (b) through (e) is exceeded, the operator of a
 community water system must give notice to the State pursuant to §141.31 and to the public as required
 by Subpart Q of this part.
 Subpart F-[ Amended]
 5. A new § 141.55 is added to Subpart F to read as follows:
 § 141.55 Maximum contaminant level goals for radionuclides.
      MCLGs for radionuclides are as indicated in the following table:
Contaminant
1. Combined radium-226 and radium -228
2. Gross alpha particle activity (excluding radon
and uranium)
3. Beta particle and photon radioactivity
4. Uranium
MCLG ./. . j£F
Zero js,. /V:?,;?' ://;'
Zero ; ::;"" ; .:-iv^v.v
' '& •' ' '' "^^SB^^i^'' '"'
^ero irf>-,,^t^. ' %^Ktev''
2ero
^y ^Ppl'*:^
Maximum Residual Disinfectant Levels          .,  •' * •> ,,
6. The title of Subpart G is revised as set out above. :M||; £\ -&,.


7. A new § 141.66 is added to Subpart G to lead as follows:""".  .
§ 141.66 Maximum Contaminant Levels for Radionuclides.
(a) [reserved]                     ^  ,
(b) MCL for combined radium-226$jpd 228. TS» maximum contaminant level for combined radium-226
and radium-228 is 5 pCi/L. The combined radMfe??.2,
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Table A - Average Annual Concentrations Assumed to Produce
A Total Body or Organ Dose of 4 mrem/yr
1. Radionuclide
2 Tritium 	

3. Strontium-90 	
Critical Organ
Total body .. . 	

Bone Marrow 	
pCi per Liter
20,000
8
(e) MCL for uranium. The maximum contaminant level for uranium is 30 ,ug/L.
(f) Compliance dates. (1) Compliance dates for combined radium 226 and 228, gross alpha particle
activity, gross beta particle and photon radioactivity, and uranium: Community water systems must
comply with the MCLs listed in paragraphs (b), (c), (d) and (e) of this sectioniix^uUJWtg [INSERT
DATE 3 YEARS AFTER PUBLICATION IN THE FEDERAL REGISTER! ^S|otopliance shall
be determined in accordance with the requirements of § 141.25 and § 141.26.  Compliafloe^with reporting
requirements for the radionuclides under Appendix A to Subpart O and Appendix A airiPfitolSubpart Q
is required on [INSERT DATE 3 YEARS AFTER PUBLICATION IN THE FEDERW! *
REGISTER].                                         .  VS".;V
                                                     •  '•' ;c£>S|S:S.\
(g) Beft Available Technologies (BATs) for Radionuclides. .The^^i^Steator, pursuant to section 1412
of the Act, hereby identifies as indicated in the following table the befetecBnplogy available for
achieving compliance with the maximum contaminant levels for combinedTriadium-226 and 228, uranium,
gross alpha particle activity, and beta particle and photon radioactivity.
Table B - BAT for combined radium-226 and radium-228, uranium, gross alpha particle activity, and beta
                               particle and photon radioactivity: -
Contaminant
1 . Combined Radium-226 and Radium-,228
2. Uranium
3. Gross alpha particle activity (Excluding
Radon and Uranium) " '' -;*s^». ., ,
4. Beta Particle^ndPhotem Radioactivity
...!:£'•' BAT
Ion Exchange, Reverse Osmosis, Lime Softening
Ion Exchange, Reverse Osmosis, Lime Softening,
Coagulation/Filtration
Reverse Osmosis
Ion Exchange, Reverse Osmosis
Radionuclides Guidance
Appendix G-11
December 8, 2000

-------
(h) Small systems compliance technologies list for radionudides.
                  Table C - List of Small Systems Compliance Technologies for Radionudides
                                          and Limitations to Use
Unit Technologies
1. Ion Exchange (IE)
2. Point of Use (POU2) IE
3. Reverse Osmosis (RO)
4. POU2RO
5. Lime Softening
6. Green Sand Filtration
7. Co-precipitation with
Barium Sulfate
8. Electrodialysis/
Electrodialysis Reversal
9. Pre-formed Hydrous
Manganese Oxide Filtration
10. Activated alumina
11. Enhanced
coagulation/filtration
Limitations
(see footnotes)
(a)
(b)
(c)
(b)
(d)
(e)
(f)

(g)
1
(i)v
Operator Skill Level
Required1
Intermediate
Basic
Advanced
Basic
;•>- '
Advanced
Basic
Raw Water Quality Range
& Considerations'
All ground waters
All ground waters ,
Surface waters uspUy require pre-
filtratife ^
Surfitfp,Waters usually require pre-
filn^fe^iSI^
Alfeiiw!tersx:r?'^^^^
?•'
Intermediate tq "' J,";3^ j Ground waters wn^^ffie water
Advanced ''^:v||;2|g[^uality
Basic to Intermedtatel^HB&eround waters
j ' iiSIEsiisBBf:.

IntennedMte .
Danced' -f'-V^j,
: '-:m
,;:.. .. v j£p*-
«' • 1! .
Advanced
/'

''MjjjjjilittiA waters
"v* v
JdB'ground waters; competing
Imion concentrations may affect
regeneration frequency
Can treat a wide range of water
qualities
 1 National Research Council (NRC). Safe Water,
 Communities. National Acadeniyjirjfe. W
2 A POU, 013
reducing^
See the A
Limitations
                                                l£very Tep: 'Improving Water Service to Small
                                                      1997.
                                     is a treatmis^iewce installed at a single tap used for the purpose of
                                        that one tap.  POU devices are typically installed at the kitchen tap.
                                              lides
                              tins highTooiscentrations of the contaminant ions.  Disposal options should be
                                   this technology.
                                    liance, programs for long-term operation, maintenance, and monitoring
                                   tisure proper performance.
carefully canskterei
b When POU devices are
mustJw provided by water
c RjC^ct water disposal options should be carefully considered before choosing this technology.  See other RO
locations described in th^;SWTR Compliance Technologies Table.
4 The combination of variable source water quality and the complexity of the water chemistry involved may make
this technology too coinplex for small surface water systems.
e Ronova] efficKOcies can vary depending on water quality.
f This technology may be very limited in application to small systems. Since the process requires static mixing,
detention basins, and filtration, it is most applicable to systems with sufficiently high sulfate levels that already
have a suitable filtration treatment train in place
8 This technology is most applicable to small systems that already have filtration in place.
h Handling of chemicals required during regeneration and pH adjustment may be too difficult for small systems
without an adequately trained operator.
'Assumes modification to a coagulation/filtration process already in place.	
December 8, 2000
                                            Appendix G-12
Radionudides Guidance

-------
Table D- Compliance Technologies by System Size Category for Radionuclide NPDWRs

Contaminant
1 . Combined radium-226 and
radium-228
2. Gross alpha particle activity
3. Beta particle activity and
photon activity
4. Uranium
Compliance Technologies' for System Size Categories
(Population Served)
25 - 500
1,2,3,4,5,6,7,8,9

3,4
1,2,3,4
1,2,4,10,11
501-3,300
1,2,3,4,5,6,7,8,9

3'4 JiftH
&.-> 3 4
_;ti^;^, Jf *t ;,,,tiJst^-^
1^3,4,5,10:6: **
3,300 - 10,000
1,2,3,4,5,6,7,8,9
.'SisU»
^•~-y
J?" 3,4
-^4-:^
m. 1,2,3,4
$$$?**,
^>,/f^«l->!t?> .-:-';;-'1
l|^fe^5,10,13:"
Note: (1) Numbers correspond to those technologies found listed|itti|ie tabl^fE of 141.66{h).""^^I^J|p'''
Subpart O - [Amended]
Appendix A to Subpart O
8. The table in Appendix A to Subpart O is amended under^ljelheading " RadioiiS^i^jritaminants'' by revising
the entries for "Beta/photon emitters", "Alpha emitters",-^d^!||&aii|ipKd radium" alflfSdding the entry for
"Uranium (pCi/L)" to read as follows:                   s-
Radionuclides Guidance
Appendix G-13
December 8, 2000

-------
ifl


\

i


z.
OS
 I
O
a
C/2

2
X
c
z
a.

<




i
Health effects language

_c

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g H

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8

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U (*
5 U
U
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§ Big-
o ,0 ~5
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C c
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CO
C
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ca
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C OT
; ^O g

' C5 ^ -g
a * •; -a
Certain minerals are radioactive and may emit forn
known as photons and beta radiation. Some people
water containing beta particle and photon radioacti
of the MCL over many years may have an increase
getting cancer.
u
•a
E
c
A
1
03
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3
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TI )
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i at

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1 0 , "a.
• SB ! ^3
ee • QJ
« : ca
c
o S2
— S
c< u
H| *^
"oil

Certain minerals are radioactive and may emit a foi
known as alpha radiation. Some people who drink
containing alpha emitters in excess of the MCL ovi
may have an increased risk of getting cancer.


CA

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1

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oo ''-
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^ w
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ts e
Some people who drink water containing radium 2
excess of the MCL over many years may have an ii
getting cancer.


w
-t;
0
o.
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3
a
B
O
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— 5 	
^
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gjf
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sy 0>
5 oc
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Some people who drink water containing uranium
MCL over many years may have an increased risk
cancer and kidney toxicity.


in
-TS
C.
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"2
3
ffl
C
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§
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*
*
*
                                                                                                      i
                                                                                                      I
                                                                                                      1
                                                                                                      1
                                                                                                      •^

                                                                                                       -•
                                                                                                       u
                                                                                                       Q.
                                                                                                       Q.

-------
Subpart Q - [Amended]
9. Appendix A to Subpart Q under I. "F. Radioactive Contaminant" is amended by revising the entries 1,2, and 3,
adding entry 4 and redesignating  endnotes 9 through  17 as endnotes  11 through 19 and adding new endnotes
number 9 and 10.
Appendix A to Subpart O of Part 141-NPDWR Violations and Other Situations Requiring Public Notice1
Contaminant
MCL/MRDL/TT Violations2
Tier of Public
Notice Required
Citation
Monitoring & Testing Procedure
Violations
Tier of Public j
Nottet Jm
^ Citation
I. Violations of National Primary Drinking Water Regulations (NPDWR)3: :," , " ' ''
******* . ,. 0 r
F. Radioactive Contaminants
1. Beta/photon emitters
2. Alpha emitters
3. Combined radium (226 &
228)
4. Uranium
2
2
2
29
141.66(4)
141.66(0)
141.66(b) -.•;
• - . ...,. '»:,-;£
"•• .••••."•*•
!41.66(e) |
is
*. VjJ
3
3
» s
"•„:>•'&,
S&^V,
>141.25(a) ,
I^Ettftifb)'
-I4fc25(a)
--Wl.26(a)
14125(a)
141.26(a)
141.25(a)
141.26(a)
******* -..;." :'".H ;:'•'" '•'
Appendix A -Endnotes
*****

       1. Violations and other situations not listed in this table (e.g., reporting violations and failure to prepare
       Consumer Confidence Reports), do not require notice, unless otherwise determined by the primary agency.
       Primacy agencies may, at their option, also require a more stringent public notice tier (e.g., Tier 1 instead of
       Tier 2 or Tier 2 instead of Tier 3) for specific violations and situations listed in this Appendix, as authorized
       under Sec. 141.202(a) and Se^JJi 1.203(a). -...'..
       2. MCL—Maximum contamni|i|feiiEl, MRDL-Maximum residual disinfectant level, TT~Treatment
       technique'-'-.> '"•:*".         T^Si-|slfi -:
       3. The term Violations of Nationdlliriniary'Drinking Water Regulations (NPDWR) is used here to include
       violations of MCL, MRDL. treatment technique, monitoring, and testing procedure requirements.
                - '"»• " ^    ' " -t
       *****

       9. The uranium MCL Tier 2 violation citations are effective [INSERT DATE 3 YEARS AFTER
      PUBLICATION IN THE FEDERAL REGISTER] for all community water systems.
   *   10. The uranium Tier 3 violation citations are effective December 7,2003 for all community water systems.
**M* * *

Appendix B to Subpart Q [Amend]
    «.       - -
10. Appendix B to Subpart Q is amended by redesignating entries 79 through 88 as 80 through 89, adding entry 79
for uranium under "G. Radioactive Contaminants", redesignating endnote entries 16 through 21 as 17 through 22
and adding endnote 16.
Radionuclides Guidance
Appendix G-15
December 8, 2000

-------
  Appendix B to Subpart O of — Standard Health Effects Language for Public
                                          Notification
Contaminant
MCLG1
mg/L
,;: MCL2
mg/L
Standard Health Effects T^ngliagpfor Fnblic
Notification
National Primary Drinking Water Regulations fNPDWR^:

G. Radioactive Contaminants:
79. Uranium16
Zero
30 Mg/L
Some people who drink water containing uHBtium in excess
of the MCL over many years may have aa increased risk of
getting cancer and kidney toxJcity. . , -

Appendix B Endnotes
      1.  MCLG- Maximum contaminant level goal
      2.  MCL- Maximaum contaminant level

      16. The uranium MCL is effective [INSERT DATE 3
FEDERAL REGISTER] for all community water systems.
*****
                                                                        BLICATION IN THE
                                                               \  *» ;f;w"V"«i?£t*;:K•"'
      Authority: 42 U.S.C. 300f, 300g-l, 3QQg-2, 300g-3,300g-4, 30^^00g-6, 300J-4,300J-9, and 300J-11.
Subpart B     Primary Enforcement Responsibility
2. Section 142.16 is amended by adding^ffreservingparagraphs (i), (j) and (k) and adding paragraph (1) to read as
follows:                            ';'          ;
§ 142.16 Special primacy requirements.       .'
*****                   i
(i) [reserved] ,-,.,.             '.':• -, |i
(j) [reserved] '•- _:~ ~-.\*\\-             ' |if".
(k) [reserved]         V              '<"'"•
(1) An appiicatkin foEapjproval of a State program revision for Radionuclides which adopts the requirements
specified in §-T^ 1 -26(a)(2)^j!) of Ibis chapter must contain the following (in addition to the general primacy
requirements enumerated in-tni >partj$ncluding that State regulations be at least as stringent as die Federal
requi^ments):
   :*» '(1) If a State chooses to use grandfathered data in the manner described in § 141.26(a)(2)(ii)(C) of this
chapter, then the State must describe the procedures and criteria which it will use to make these determinations
(whether distribution system or entry point sampling points are used).
              (i) The decision criteria that the State will use to determine that data collected in the distribution
system are representative of the drinking water supplied from each entry point to the distribution system.  These
detenninatumstnust consider:
     ' ;        (A) All previous monitoring data.
              (B) The variation in reported activity levels.
              (C) Other factors affecting the representativeness of the data (e.g. geology)
      (2) A monitoring plan by which the State will assure all systems complete the required monitoring within the
regulatory deadlines. States may update their existing monitoring plan or use the same monitoring plan submitted
for the requirements in §142.16(e)(5) under the National Primary Drinking Water Regulations for the inorganic and
December 8, 2000
                                           Appendix G-16
Radionuclides Guidance

-------
organic contaminants (i.e. the Phase II/V Rules). States may note in their application any revision to an existing
monitoring plan or note that the same monitoring plan will be used.  The State must demonstrate that the monitoring
plan is enforceable under State law.


3. Section 142.65 is added to read as follows.
§ 142.65 Variances and exemptions from the maximum contaminant levels for radionuclides.
(a)(l) Variances and exemptions from the maximum contaminant levels for Combined Radium-226 and Radium-
228, Uranium,  Gross alpha particle activity (Excluding Radon and Uranium), and Beta Particle and Photon
Radioactivity. The Administrator, pursuant to  section 1415(a)(l)(A) of the Act, hereby identifies the following as
the best available technology, treatment techniques, or other means available for achieving complBBKe with the
maximum contaminant levels for the radionuclides listed in §141.66 (b), (c), (d), and (e) of thitfidiapter, for the
purposes of issuing  variances and exemptions,  as shown in Table A of this paragraph.-:: x
Table A. BAT for Radionuclides Listed Jn§ 141.6i-||s||||, ,
Contaminant
Combined Radium-226 and Radium-228
Uranium
Gross alpha particle activity (Excluding Radon and
Uranium)
Beta Particle and Photon Radioactivity
f
Ion Exchange, Reverse Osmosis,
Ion Exchange^ Reverse Osmosis,
Coagulatioa/Fitoaticm
LrmeSoftenmg '
Lime Softening,
Reverse Osmosis ;,
jten pccbai^e, Reverse-Osmosis
In addition, the Administrator hereby identifies the following as the bestavaflable technology, treatment techniques,
or other means available for achieving compliance with the maximum contaminant levels for the radionuclides listed
in §141.66 (b), (c), (d), and (e) of this chapter, for the purposes of issuing variances and exemptions to small
drinking water systems, defined here as thcse-serving 10,000 persons or fewer, as shown in Table C on this section.
Radionuclides Guidance
Appendix G-17
December 8, 2000

-------
                Table B. List of Small Systems Compliance Technologies for Radionuclides
                                         and Limitations to Use
Unit Technologies
1. Ion Exchange (IE)
2.. Point of Use (POU2) IE
3. Reverse Osmosis (RO)
4. POU2RO
5. Lime Softening
6. Green Sand Filtration
7. Co-precipitation with
Barium Sulfate
8. Electrodialysis/
Electrodialysis Reversal
9. Pre-formed Hydrous
Manganese Oxide Filtration
10. Activated alumina
11. Enhanced
coagulation/filtration
Limitations
(see footnotes)
(a)
(b)
(c)
(b)
(d)
(e)
(f)

(g)
(a), 00
A
(i) ?•
Operator Skill Level
Required1
Intermediate
Basic
Advanced
Basic
Advanced ,.;%.;,;>
Basic ,:
~ ~ .
Intermediate to
Advanced : ; ;^ ; - v^,.^:l
Basic to Intermfa^^l
_ • .^%'pfisB
-i-' *•*>'+.<%&]
Intermediate.'' '"v^
" :ic*
y

Advanced ^ *f ~**
Raw Water Quality Range
& Considerations'
All ground waters
All ground waters
Surface waters usually require
pre-filtration ^ .
Surfaeecwatersiasually require
,,,

tHbund wate1^^Kte^:water
All ground waters ~"
**•_
iSiipPd waters
?;-.-'^*«",
/. . • '.^ :'..*»*:i; •".-.: i- ••.
V <****•.&«:*;«";<&*;- - •. x
Al^^flpmd waters; competing
anion concentrations may affect
.regeneration frequency
Can treat a wide range of water
qualities
 1 National Research Council (NRC)  StjjJUWater from Every Tap: improving Water Service to Small
 Communities.  National Academy Pre^l^ashingtaii, D.C. 199$
 2 A POU, or "point-of-use" technology; is a treatnadeviceianaalJed at a single tap used for the purpose of
 a tre
 at that
details.    _
   dionuclides
                                                          evices are typically installed at the kitchen tap.
                                            itrations of the contaminant ions. Disposal options should be
                                            logy.
                            for compliance, programs for long-term operation, maintenance, and monitoring
                                        proper performance.
reducing a
Seethe
Limitati
'The
carefully
"When
must be provided by w;
c Reje^iwater disposal option fSfaoljii-be carefully considered before choosing this technology.  See other RO
limitations described in the'SWTR Compliance Technologies Table.
d ^Ift combination of variable source water quality and the complexity of the water chemistry involved may
inaice this technology too Complex for small surface water systems.
'Removal efficiencies can vary depending on water quality.
fThis technologyjnay be very limited in application to small systems. Since the process requires static mixing,
detention basins, and filtration, it is most applicable to systems with sufficiently high sulfate leveb that already
have a«titab!efiltration treatment train in place
8 This technology is most applicable to small systems that already have filtration in place.
h Handling of chemicals required during regeneration and pH adjustment may be too difficult for small systems
without an adequately trained operator.
1 Assumes modification to a coagulation/filtration process already in place.          	  	__^_
December 8, 2000
        Appendix G-18
                                                                                Radionuclides Guidance


-------
Table C. BAT for Small Community Water Systems for the Radionuclides Listed in § 141.66

Contaminant
Combined radium-226 and
radium-228
Gross alpha particle activity
Beta particle activity and photon
activity
Uranium
Compliance Technologies' for System Size Categories
(Population Served)
25 - 500
1,2,3,4,5,6,7,8,9

3,4
1,2,3,4
1,2,4,10,11
501 -3,300
1,2,3,4,5,6,7,8,9
3,4 ,;,:;,s
-'!S/;.t:;;O
1,2, 3, 4 .<€life
:' .? ' :-:>ste:
V;';-*;
1,2,3,4,5, ljp;-H
3,300-10,000
1,2,3,4,5,6,7,8,9
..-. >
.-:>•'' 3'4
U. '••<••
% 1,2,3,4
'tfZi. •• •
,W.ii?i.^\
.U' i?->>"*'- '••
'^£fjjjj$k!f5, IQyll
Note: (1) Numbers correspond to those technologies found listed in thejabldSB of this paragrajjgp^^^f "
(2) A State shall require community water systems to install and/or
A of mis section, paragraph (1), or in the case of small water systems^
                                                                        iient technology identified in Table
                                                                          |.,l 0,000 persons or fewer), Table
B and Table C of this section, as a condition for granting a variance except^l|ppi|ide(tin paragraph (a)(3) of this
section. If, after the system's installation of the treatment technology, the system cannot meet the MCL, that system
shall be eligible for a variance under the provisions of section 1415(a){l)(A) of fhjriifct
(3) If a community water system can demonstrate through comprehensive engineering assessments, which may
include pilot plant studies, that the treatment technologies identified m^SsSecjion would only achieve a de minimus
reduction in the contaminant level, the State may issue a schedule of pdiiijfii&^tiiat requires the system being
granted the variance to examine other treatment technologies as a conditionaof obtaining the variance.
(4) If the State determines that a treatmenftechnology identified undcrparagraph (a)(3) of this section is technically
feasible, the Administrator or primacy StateSnay require the system to install and/or use that treatment technology in
connection with a compliance schedule issued under the provisions of section 1415(a)(l)(A) of the Act.  The State's
determination shall be based upon studies by the system and other relevant information.
(5) The State may require a community water system to use bottled water, point-of-use devices, point-of-entry
devices or otheoneans as a coa^tidffiO^granting a variance or an exemption from the requirements of § 141.66 of
this chapter, to avoid ah unreasonabli|iKk4o health.
(6) Community waiter ^systems that usibottled water as a condition for receiving a variance or an exemption from
the requirements of §141.66 of this chapter must meet the requirements specified in either paragraph (g)(l) or (g)(2)
and (g)(3) of §142.52^
(7) Community water systems that use point-of-use or point-of-entry devices as a condition for obtaining a variance
or an exemption from the radieinicfideS'NPDWRs must meet the conditions in §142.62 (h)(l) through (h)(6).
Radionuclides Guidance
                                             Appendix G-19
December 8, 2000

-------

-------
Appendix H
       •m
        son
Values (^ Beta and Photon

-------

-------
                       Derived Concentrations of Individual
                  Beta Particle and Photon Radioactivity Emitters
                                     (in pCi/L)
Nuclide
('half-life of 24
hours or less)
H-3 (HTO)
Be-7
C-11
N-13
C-14
C-15
O-15
F-18"
Na-22
Na-24
Si-31 *
P-33
P-32
S-35 (Inorg)
CI-36
CI-38 *
K-42 *
Ca-45 ', ':',>•,.
Ca-47 C
Sc-46
Sc-47
Sc-48
V-48
O51
Mn-52
Mn-54
Mn-56"
Fe-55
Fe-59
Co-57
Co-58
Co-58m
C6-60
1976 limits
(based on critical organ at 4 mrem/yr)
20,000
6,000
NC

2,000'


2,000
400

3,000

30
500
700
..•-;.. 1.000
•"..'. .*£'. '•'• '• ' 900
"\ '-"SiU., 10
.J&w.J'S.rL"
„.,, .:52i;£|:L:, . 80
•'•';'; ;'il:;.. ':--:B "" 1°°
•"•:. ::*;;..; . , '"~:" soo
•".;••: '. -^ ••, 80
90
6,000
90
300
300
2,000
200
1,000
300
9,000
100
December 8, 2000
Appendix H-2
Radiomtclides Guidance

-------
Nuclide
("half-life of 24
hours or less)
Ni-59
Ni-63
Ni-65 *
Cu-64*
Zn-65
Zn-69*
Zn-69m *
Ga-67
Ga-72 *
Ge-71
As-73
As-74
As-76
As-77
Se-75
Br-82
Rb-82
Rb-86
Rb-87
Rb-88
Rb-89
Sr-82 ^,",..
Sr-85 < .;&£.•£-
Sr-85m x'lvjl^
Sr-89 •;•
Sr-90 ^ :":-,.

Sr-91 "...
Sr-92
Y-SO
•y*i
Y*1m*
Y-«Z* ^
Y-49
Zr-93
Zr-95
Zr-97 *
Nb-93m
Nb-94
1976 limits
(based on critical organ at 4 mrem/yr)
300
50
300
900
300
6.000
200
NC
100
6,00^
LOW;
iod<
eo
200
. '-';:;5PO:
X; "-^^ii.
yr,v "^ ^|lj-
rf- " J
600
/f:.;';s; ., 300.
/ffiF"" *,• ^4C
.;«^'.' ;
•'•';";!" ,-, -^'... kir*
;;«:• iwjr- -.-• NC
^j -•-Sil ;-": NC
^ "*'-' ' 900
;• 21,000
'£ .:•-,, 20
::.;;;:_;Vf;, ^l|i^ 8

' ": l':'--;--:^, 200
I1"': '.??' 200
•:• 60
90
9,000
200
90
2,000
200
60
1,000
NC
Radionuclides Guidance
Appendix H-3
December 8, 2000

-------
Nuclide
("half-life of 24
hours or less)
Nb-95
Nb-95m
Nb-97 *
Nb-97m
Mo-99
Tc-95
Tc-95m
Tc-96
Tc-96m *
Tc-97
Tc-97m
Tc-99
Tc-99m
Ru-97
Ru-103
Ru-105 *
Rh-105m
Ru-106
Rh-103m *
Rh-105*
Rh-106
Pd-100
Pd-101

Pd-103
Pd-107
Pd-109
Ag-105
Ag-108
Afl-108m
Ag-109m
Ag-110
AgrllOm ._..
Ag-111
Cd-109
Cd-115
Cd-115m
ln-113m*
irv114
1 976 limits
(based on critical organ at 4 mrem/yr)
300
NC
3,000

600
NC
NC
300
30,000
6,000
1,000
900
20,000
1,000
200
NC •

30
30,000
.:;•:>'•" 300
. . :£•' ,:.: . 	 NC
..' .'&: ' 4 NC
'".:" .*:\ - ' NC
• iafegfefeV ' nriri
, .. ,.,Ss»«V •- 9°0
:•• '*'•'•'&•• • NC
• " •••:•-_ : '••:;-.:: ' 300
\ 300

NC


90
100
600
90
90
3,000

December 8, 2000
Appendix H-4
Radiomtclides Guidance

-------
Nuclide
(*half-lifeof24
hours or less)
ln-114m*
ln-115
ln-115m*
Sn-113
Sn-121
Sn-121m
Sn-125
Sn-126
Sb-122
Sb-124
Sb-125
Sb-126
Sb-126m
Sb-127
Sb-129
Te-125m
Te-127
te-127m
Te-129
Te-129m
Te-131m
Te-131 ^_
Te-132 .-titfc.,;.
[-122 % f'1"lf^
1-123 *••**
1-125 . . " •
1-126
[-129
l-f30
1-131
1-132,*
1-133- 	 ^
J-134?
1-135*
Cs-131
Cs-134
Cs-134m*
.Cs-135
1976 limits
(based on critical organ at 4 mrem/yr)
60
300
1,000
300
NC
NC
60
NC,
90
60
*>^fi^
N^J"1
p&
NC
,-, :.Ww
,... ••^•isdij*
/''•'" 1 ®$
,i , 200
(.:•" 2,000
,:^'"' ,4; 9d.
, ^" i^b ,._-, :'«c
*.-. :i^ •'-• ' 200
< :;;. ; ^^ - QQ
''• J^ISj-.
T.'., .-'- '-c-l8it-!|.:; ':"'' NC
; . ".--tC.,-. V' ?.•:,•" i
•-;.-," ' ,"'-":*• ' •:•••••"
'" ' i< , 3
] , '~. 1
NC
3
,; 90
10
100
30
20,000
80
20,000
900
pyr^
\l.;i£fi&^
\^. |.;. ^. .^
• ri '
*!
Radionudides Guidance
Appendix H-5
December 8, 2000

-------
Nuclide
('half-life of 24
hours or less)
Cs-136
Cs-137
Cs-138
Ba-131
Ba-133
Ba-133m
Ba-137m
Ba-139
Ba-140
La-140
Ce-141
Ce-143
Ce-144
Pr-142 *
Pr-143
Pr-144
Pr-144m
Nd-147 *
Nd-149 *
Pm-147
Pm-148
Pm-148m
Pm-149 . ..fll. •
Sm-151 ••:; ^;*'j:
Sm-153 " '
Eu-152*
Eu-154
Eu-156'
Eu-156
Gd-153
Gd-159 *
Tb-158 .„.._
Tb-160
Dy-165 *
Dy-166
Ho-166
Er-169
Er-171 *
1976 limits
(based on critical organ at 4 mrem/yr)
800
200
NC
600



NC
90
eo
3001
100
NC
90
too
NC:

NC
900
'" NC
NC
.. '.^:-, •'•:.• ': NC
'.'Z'L-,.. '" ' 100
;•:.; •. '•;':,:r:.:;;. 1,000
: A . . , ^ . .:•,-.,,, ,, 200
: :" f :;,;/. -., ' 200
•-•::c- , , 60
.- 600
NC
600
200
NC
100
1,000
100
90
300
300
December 8, 2000
Appendix H-6
Radionuclides Guidance

-------
Nuclide
(•half-life of 24
hours or less)
Tm-170
Tm-171
Yb-169
Yb-175
Lu-177
Hf-181
Ta-182
W-181
W-185
W-187*
Re-183
Re-186
Re-187
Re-188*
Os-185
Os-191
Os-191m*
Os-193
lr-190
lr-192
lr-194 *
Pt-191 .via*.
R-193< &L*i ;•>''.
Pt-193m %<>:r ".','• r
Pt-197 N -
Pt-197m* ^x ;,''; 2
Au-196,,-;?^
Au-}38
4^!»9
*&jr197
;*fe-197m
HBW98;
Hg-203
TI-200
TI-201
TI-202
TI-204
T.I-207
1976 limits
(based on critical organ at 4 mrem/yr)
100
1,000
NC
300
300
200
100
1,000.
300?
m
*M
3061
9,0*
\4
200
^OQ
--••awl
^"'!''' «;'dd(ft
.. 200
< ' 600
?-" ' /' 10tf';
f^,- .^-? .!l»6
•!•; •'li£-i. .•-;.r-''300
"• ! ' / ; , , X: '- 3,000
:. :'-£:- 3,000
^ v !\j; / 300
S;.U "" 3.000
^.''^ , 600
' t \: 100
NC
NC
NC

NC
NC
NC
300
300

                                                                              «-  »*>'j^,'W«K.
                                                                    $•>
Radionuclides Guidance
Appendix H-7
December 8, 2000

-------
Nuclide
fhalf-Iife of 24
hours or less)
TI-208
TI-209
Pb-203
Pb-209
Pb-210
Pb-21 1
Pb-212
Pb-214
Bi-206
Bi-207
Bi-212
Bi-213
Bi-214
Fr-223
Ra-225
Ra-228
Ac-227
Ac-228
Th-231
Th-234
Pa-233
Pa-234
Pa-234m
u-237 ;••; ;
U-240
Np-236
Np-238
Np-239
Np-240
Nj>-240m
Pu-241
Pu-243
Am-242m
Bk-249
1976 limits
(based on critical organ at 4 mrem/yr)


1,000
NC
NC
NC
NC
NC.
Ntf
260
*:'\.
NC
NC
NC
NC
" . .*.'
- • . ,"'f
N0
NC
NC
NC
.... 	 300
/;'. :. NC
, ' " ^ , ,1
; ., . :";:is2fc-: NC
•:••:• • ,, x;r?l;;r" * NC
,.:••;:, :.-pjJi|r. \ •„;
" -"'"'-ri.' v . NC
: NC
NC

NC
NC
NC

December 8, 2000
Appendix H-8
Radionuclides Guidance

-------

-------
References

-------
                                                                        • a-"-.'  ."''' '




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                              This page has been intentionally left blank.
                                            •M--
December 8, 2000
References-2
Radionudides Guidance

-------
Goodrich, J.A., Adams, J.Q., Lykins, B.W., Jr., and Clark, R.M. Safe Drinking Water from Small
Systems: Treatment Options. JAWWA. 84(4). p. 49. May 1992.

National Research Council (NRC).  Safe Water From Every Tap: Improving Water Service to Small
Communities. National Academy Press. Washington, DC.  1997.

USEPA. Office of Drinking Water. Suggested Guidelines for Disposal of Drinking Water Treatment
Wastes Containing Naturally-Occurring Radionuclides (July 1 990 draft).
USEPA. National Primary Drinking Water Regulations; Radionuclides; Proposed Rule. Federal
Register. Vol. 56, No. 138, p. 33050.  July 18, 1991.                     '   '",":'
                                                                 '•-I'i'iO'}:-': <

USEPA. Technologies and Costs for the Removal of Radionuclides from
Prepared by Malcolm Pirnie, Inc. July 1992.

                                                    ..-' '  •.'^''-•'              K'lb^;''
USEPA. Office of Ground Water and Drinking Water.  SuggesU&i&mdelines for DisposaTqf Drinking
Water Treatment Wastes Containing Radioactivity (June
USEPA. Performance Evaluation Studies Supporting Administration ixf&ieliiijteieat, Water Act and the
Safe Drinking Water Act. Federal Register. Vol. 61,No;=j%p. 37464. sJuJl|£S, 1996.
USEPA.  National Primary Drinking Water JKegulations^r&Sy^^^f&)ds for Radionuclides; Final
Rule and Proposed Rule. Vol. 62, No. 43, p.' 10168. Jyd|rch S^^^p'

USEPA.  Performance Evaluation Studies Supporting Administration of the Clean Water Act and the
Safe Drinking Water Act. @ FederafcRegister. Vol. 62, No. 113, p. 32112. June 12, 1997.


USEPA.  Perfdt^ance Based Me&jfaement System. Federal Register. Vol. 62, No. 193, p. 52098.
October 6, 1997.              fc.
USEPA.  Manualforthe G&tificaii^j>f Laboratories Analyzing Drinking Water.  EPA 8 1 5-B-97-00 1 .
1997.       .-•.:,";;'"'••".
USEPA.  Announcement ofSmdUlystems Compliance Technology Lists for Existing National Primary
Driitking Water Regulations and Findings Concerning Variance Technologies. Federal Register. Vol.
63, too. 151, p. 42032.  August 6, 1998. (EPA 1998a).
USEPA.  Small Syst&p Compliance Technology List for the Non-Microbial Contaminants Regulated
Before 1996. ER&-815-R-98-002. September 1 998. (EPA 1998b).

USEPA.  Actual Cost for Compliance with the Safe Drinking Water Act Standard for Radium-226 and
Radium-228. Final Report. Prepared by International Consultants, Inc. July 1998.  (EPA 1998c).

USEPA.  Revised Cost Estimates of Radiochemical Analysis.  Prepared by EPA and Science Applications
International Corporation (SAIC). April 1999. (EPA 1999)
Radionuclides Guidance
References-3
December 8, 2000

-------
 USEPA. Technologies and Costs for the Removal of Radionticl ides from Potable Water Supplies. Draft.
 Prepared by International Consultants, Inc. April 1999.  (EPA 1999a).


 USEPA. Small System Compliance Technology List for the Radionuclides Rule. Prepared by
 International Consultants, Inc. Draft. April 1999. (EPA 1999b).


 USEPA. State Implementation Guidance for the Consumer Confidence Report (CCR) Rule. EPA 816-R-
 99-008. August 1999.
USEPA. Radionuclide Notice of Data Availability. April 2000.
                                          *,-*--
                                         «:f&
                                         ^|.;::
December 8, 2000
References-4
Radionuclides Guidance

-------