Transfer of Water Treatment Plant Waste Containing Radionuclides

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Alternatives for Disposal are Influenced by. . . . Grouping of radionuclides and co-happening contaminants in the waste stream Hazardous WasteTechnologically Enhanced Naturally Occurring Radioactive Material (TENORM) Low-Level Radioactive Waste (LLRW)Mixed WasteFederal, State,

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´╗┐Transfer of Water Treatment Plant Waste Containing Radionuclides

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Options for Disposal are Influenced by. . . Convergence of radionuclides and co-happening contaminants in the waste stream Hazardous Waste Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) Low-Level Radioactive Waste (LLRW) Mixed Waste Federal, State, & Local Regulations Disposal office approaches Type of residuals Liquid or strong

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Definitions for Waste Hazardous Waste Technologically Enhanced Naturally Occurring Radioactive Material (TENORM) Low-Level Radioactive Waste (LLRW) Mixed Waste

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Hazardous Waste Regulated under RCRA Hazardous waste is strong waste: Not barred from direction under 40 CFR 261.4(b) Exhibits harmfulness, destructiveness, reactivity, or ignitability criteria recorded under 40 CFR 261.3(a)(2) and (b) Presence of radionuclides does not ITSELF make the waste perilous

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TENORM Regulated by various government controls Defined as normally happening materials whose radionuclide fixations or potential for presentation is improved subsequently of human exercises Includes squander streams created by water treatment plants Also incorporates mining, compost generation, and oil and gas creation.

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LLRW Defined by The Low-Level Radioactive Waste Policy Act Not abnormal state radioactive waste, spent atomic fuel, or side effect material; and, The Nuclear Regulatory Commission (NRC)...classifies as LLRW

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LLRW Can contain source or uncommon atomic material Radium (Ra) is not source or repercussion material by definition Uranium (U) & thorium (Th) are source material and might be liable to NRC authorizing necessities HOWEVER. . .

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LLRW: Uranium & Thorium If U or Th makes up <0.05% by weight (totaling under 15 lbs.), it is source material an "immaterial amount" and absolved from NRC Regulations Approximately 335 pCi/g for characteristic U

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>0.05% U/TH by weight (totaling < 15 lbs.) Mixed waste subject to general permit from NRC or Agreement State Hazardous Waste + = >0.05% U/TH by weight (totaling > 15 lbs.) Mixed waste subject to particular permit from NRC or Agreement State Hazardous Waste + = Mixed Waste Regulated under RCRA and the Atomic Energy Act (AEA) Contains both perilous waste and source. . . on the other hand side effect material subject to the AEA

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Statutes and Regulations

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Things to Consider Numerous government directions No elected waste transfer control particularly for TENORM Key definitions differ among directions States, region, and waste transfer office may have extra necessities

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RCRA 42 USC 6901 et. seq. The distinguishing proof, administration, and transfer of strong squanders (counting slime) If you create strong waste, you should figure out if the waste is unsafe Use a technique portrayed in 40 CFR 262.11

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RCRA: Hazardous Waste Solid waste displaying poisonous quality, destructiveness, reactivity, or ignitability attributes is dangerous Requirements rely on upon the measure of risky waste delivered month to month and the measure of perilous waste put away on location at any given time Large Quantity, Small Quantity, or Conditionally Exempt Small Quantity "Support to Grave" obligation

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RCRA Subtitle C necessities apply to unsafe waste transfer Hazardous Waste Landfill LLRW Landfill RCRA Subtitle D prerequisites apply to non-perilous waste strong waste transfer Municipal Solid Waste Landfill (MSWLFs) necessities Some MSWLFs can acknowledge business strong waste, nonhazardous muck, CESQG squander, and modern nonhazardous strong waste Hazardous Waste Landfill LLRW Landfill RCRA

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Clean Water Act (CWA) 33 USC 1251 to 1387 Direct releases under a National Pollutant Discharge Elimination System (NPDES) allow Discharges to a freely claimed treatment works (POTW) Federal NPDES controls don't set particular cutoff points on radionuclides in releases EPA controls on the utilization and transfer of the sewage slop delivered by POTWs at present don't cover radioactive material

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CWA Systems ought to: Contact the state NPDES program to figure out whether the framework needs a NPDES or other allow Contact the state NPDES program to figure out whether the framework is equipped for meeting the appropriate nearby breaking points Contact their POTWs to guarantee that the squanders will be acknowledged

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SDWA 42 USC 300f et seq. EPA required to create least prerequisites for underground infusion control (UIC) programs Stay tuned. . .

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DOT Regulations 49 CFR 171 to 180 Govern delivering, marking, and transport of perilous materials DOT meaning of dangerous incorporates radioactive materials HOWEVER. . .

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DOT exempts, "other characteristic materials or metals... at the point when these have been subjected to physical or concoction preparing, when the handling was not with the end goal of removing radionuclides...provided that their radionuclide focus does not surpass 10 times the movement fixation in the table in 49 CFR 173.436." For instance Uranium is recorded in the table in 49 CFR 173.436 at 27 pCi/g Radium-226 and - 228 are recorded at 270 pCi/g Therefore, a framework would need to transport more than 270 pCi/g of uranium or 2,700 pCi/g of radium before meeting the "10 times" exclusion limit DOT: Exemptions

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AEA 42 USC Chapter 23 AEA manages the improvement and utilization of atomic offices, and the creation, era, and transfer of source, uncommon atomic, and side effect material Uranium and thorium are source material NRC has exempted some source material Uranium or thorium makes up <0.05% by weight

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State TENORM Regulations Currently controlled by 13 states http://www.tenorm.com/regs2.htm#States

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Residual Type Solid Residuals Liquid Residuals

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Liquid Residual Stream Brine Backwash Water Rinse Water Acid Neutralization Water Concentrate Solids Spent Resins Spent Filter Media Spent Membranes Sludges Waste Streams

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Solid Residuals by Treatment Type

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Liquid Residuals by Treatment Type

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Disposal Options Direct Discharge to POTW Underground Injection Landfill

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Disposal Options

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Incineration Evaporation lakes Surface impoundments Sludge dewatering Other Options? Middle of the road preparing strategies each making its own remaining stream Not energized unless there is a shown advantage and the advantages are weighed against potential dangers & dangers Landspreading or soil blending

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CWA Need available and suitable getting body Must have a National Pollutant Discharge Elimination System (NPDES) allow Federal NPDES controls don't set particular breaking points on radionuclides in releases yet: State hostile to debasement approaches Source water security arrangements Co-happening contaminant limits set in NPDES Liquids: Direct Discharge May restrain the utilization of this transfer choice

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Liquids: POTW Discharges to a POTW will have NPDES allow System may require nearby allow or contract Both the framework and the POTW are in charge of: Preventing the presentation of any toxins that may meddle with the POTW treatment handle, sully POTW sewage slime, or abuse POTWs NPDES allow Meeting actually based neighborhood limits (TBLLs) Meeting pretreatment directions POTW proprietors can decline to acknowledge squander

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Solids: Landfill Determine if the waste is dangerous through information of the waste era handle, logical testing, or both Toxicity Characteristic Leaching Procedure (TCLP) (EPA Method 1311) Determine if squander contains any "free fluids" Perform the Paint Filter Liquids Test (or PFLT; EPA SW 846 Method 9095) Conduct moderate preparing to evacuate any fluids No government prerequisite to test residuals particularly for radionuclides No particular elected control representing landfill transfer of water treatment plant solids or slops containing TENORM

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Solid Waste Landfill Municipal strong waste landfills may acknowledge: Non-risky, strong, TENORM squanders from all water frameworks Hazardous waste from Conditionally Exempt Small Quantity Generators Industrial strong waste landfills may likewise acknowledge: Non-unsafe strong TENORM waste

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Hazardous Waste Landfill May acknowledge perilous waste from all generator classes Hazardous waste from Large and Small Quantity Generators must meet RCRA Land Disposal Restriction necessities (40 CFR 268.40) Some unsafe waste landfills have unequivocal allow conditions while others may need to demand state endorsement before tolerating TENORM squanders

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LLRW Landfills Licensed by NRC or by a state under concurrence with NRC Barnwell - South Carolina After June 30, 2008, will acknowledge squander just from associations in South Carolina, Connecticut, and New Jersey Richland - Washington Accepts certain sorts of TENORM (despite the fact that not dangerous or blended) squanders from all states Envirocare - Utah Has devoted TENORM transfer and is the main LLRW landfill approved to acknowledge certain sorts of blended waste

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Solids Residual Disposal Use transitional preparing to isolate out the fluids No Identify the quality and amount of the leftover Is the waste a strong as indicated by the PFLT? Yes For fluid residuals transfer, see Liquid Residuals Decision Tree 2 Sludge, Resin, Granular Media, AA Media, Spent Membranes Dispose in a strong waste landfill Dispose in a strong waste, risky waste, or LLRW landfill, or any landfill authorized by the state to acknowledge TENORM waste No Is the waste unsafe? Does the waste contain radionuclides? No Yes Dispose in a perilous waste landfill and meet all RCRA Subtitle C prerequisites Does the waste contain radionuclides? No Dispose in a landfill authorized to acknowledge blended waste** Yes Does the waste contain non-exemp

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