Colorado: Current Waste Disposal Approaches and Challenges 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 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)

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: 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 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

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