TENORM Colorado: Current Waste Disposal Approaches and Challenges - PowerPoint PPT Presentation

TENORM Colorado: Current Waste Disposal Approaches and Challenges Jim Grice, Radioactive Materials Unit Leader Colorado Department of Public Health and Environment

Disposal as Solid Waste  Administrative Release Levels  Below may be treated without regard to their radioactive constituents  Combined Radium – 3 pCi/g above background  Natural Uranium – 30 pCi/g above background  Natural Thorium – 3 pCi/g above background  Specific Radioactive Materials License Threshold  Combined Radium – 50 pCi/g above background  Natural Uranium – 339 pCi/g above background  Natural Thorium – 55 pCi/g above background

Disposal as Solid Waste  Solid Waste RCRA Subtitle D  Municipal Solid Waste  Industrial  Restrict Dose to Public to 25 mrem annually  RESRAD (worker and 1000 yr resident)  CAP-88 or MILDOSE (Radon offsite estimates if methane collection system is used)

Disposal as Solid Waste  EDOP Revision with CDPHE Approval  Acceptance Criteria  Total Volume  Operations consistent with Dose Assessment  Permit or Certificate of Designation Revision/Modification  Local Government Approval  Required per the Colorado Solid Waste Act

Challenges  Concentration limits for RCRA D  What wastes should be characterized?  What is an appropriate or statistically defensive characterization?  How long is a waste profile good for?

Concentration limits  Upper bounds of 50 pCi/g in an engineered landfill  Likely less than 100% of waste volume  0.05% by mass for U and Th  Regulatory limit.  Pb, Po, etc. Unsupported Daughters  In general these can be at 50 pCi/g as well  Worker dose is more problematic than resident farmer.

Waste Streams of Interest Water Treatment: O&G E&P:  Drinking Water  Filter socks  IX Media  Tank bottoms  Green Sand  Horizontal cuttings in uranium bearing formations  HMO  Filter press cake  Soils from discharge area/impoundment  Residual materials dislodged during cleaning and maintenance activities on the  Wastewater (if there is a discharge to the following: system from another water treatment activity)  Crude oil pipeline (pipe scale scraping/rattling/wire brushing)  Biosolids  Natural Gas scrubbers, compressors,  Drying beds reflux pumps, control valves and  Industrial (any treatments that would product lines likely concentrate metals)  Gas/oil separators  Any Filter media  Dehydration vessels  Soils from discharge  Liquid natural gas (LNG) storage tanks area/impoundment

How to characterize?  How many samples is enough?  Must have an adequate confidence that materials do not exceed limits  EPA SW-846  Sampling plans and statistical methods for establishing confidence  Generators and Disposal Facilities need to be informed

Waste Profile Validity  How long can a waste profile be used?  Periodic sampling and use of statistical tests to verify that the dataset is still valid for ongoing waste streams  Should be spelled out in Waste Characterization Plan

Solid Waste Landfill Disposal  What it can and should be:  Safe, Protective, Cost effective, Sensible solution  The Devil is in the details:  Waste Identification, Dose assessments, Concentration limits, Waste characterization and acceptance

Thank You! Questions? Jim Grice, Radioactive Materials Unit Leader Colorado Department of Public Health and Environment james.grice@state.co.us – 303-692-3371