Compliance Options and Technical Guidance

There are a number of options available to resolve radionuclide violations, however there are many considerations associated with each of these options. Ultimately, identifying a viable option for a system can be an extreme challenge.

The U.S. Environmental Protection Agency has a number of documents available online that will offer general guidance on various compliance options.

Colorado specific guidance on many issues of concern can be found below.

The Phase 3 summary report developed by Malcolm Pirnie, Inc. shows that traditional treatment and disposal methods for radionuclide compliance can be extremely costly. Readers should be aware that there were limitations in certain areas of these evaluations, such as non-treatment options like blending or consolidation, or certain waste handling options such as discharges to wastewater treatment facilities – for additional information on these impacts, please see the presentation materials for the first Phase 4 regional meeting.

Phase 3 Treatment and Disposal Evaluation Summary Report

Executive Summary
Phase 3 Summary Report
Appendix A CO-RADS System Information
Appendix B Radionuclide Risk Assessment and Analysis
Appendix C Interim Measures and Point of Use
Appendix D Water Sampling and Travel Plan
Appendix E Feasible Technology Memo
Appendix F Worker Exposure Modeling Memo
Appendix G Bench and Pilot Testing Plan
Appendix H POU Workshop Slide pdf file
Appendix I Draft Non-Treatment Options Matrix
Appendix J Final Bench and Pilot Testing Report
Appendix K Additional Info Provided in CORADS Reports
Appendix L EPA Cost Estimates

Appendix M CORADS Impact on Rates Analysis
Appendix N Evaporation Basin and Labor Costs
Appendix O Updated Liquid Residuals Flowchart
Appendix P Final Residuals Sampling Results
 

In light of the high costs for traditional approaches identified in Phase 3, the Water Quality Control Division will continue to work with systems and waste handling agencies in Phase 4 to develop more cost effective alternatives.

• Guidelines for Preliminary Engineering Report or Request for Extension
• Other Treatment/Compliance Options to Consider
• Example Alternative Evaluations
• Point-of-Use Treatment
• How to Hire an Engineer
   

Waste streams generated by radionuclide removal processes may fall under the regulatory jurisdiction of multiple program areas within the department, including the Solid Waste, Radiation Management, and Wastewater Permitting Programs. EPA and local health departments may also have jurisdiction over certain waste handling practices. On average, 60 percent of the capital costs estimated in Phase 3 were associated with waste handling basins. For some systems, these basins made up more than 80 percent of estimated capital costs. Alternative disposal options or basin design could provide significant savings. However, it is challenging to identify and address all associated waste handling requirements. The following documents should provide further guidance on this issue.

• Interim Policy and Guidance Pending Rulemaking for Control and Disposition of Technologically-Enhanced Naturally Occurring Radioactive Materials in Colorado
• Waste Disposal Options Flowchart
• Waste Disposal Contact Information
   

• Phase 4 Kick-Off Meeting - March 2009
• Phase 4 Meeting II - June 2009