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

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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


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TENORM

Colorado: Current Waste Disposal Approaches and Challenges

Jim Grice, Radioactive Materials Unit Leader Colorado Department of Public Health and Environment

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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

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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)

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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

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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?

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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.

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Waste Streams of Interest

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

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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

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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

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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

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Thank You!

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

Questions?