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Treatment Residual Disposal Options

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Treatment Residual Disposal Options TreatmentTreatment ResidualResidual DisposalDisposal OptionsOptions 1 OverviewOverview ¾¾ AcronymsAcronyms && AbbreviationsAbbreviations ¾¾ DisposalDisposal ConsiderationsConsiderations ¾¾ LiquidLiquid ResidualResidual TypesTypes ¾¾ SolidSolid ResidualResidual TypesTypes ¾¾ LiquidLiquid ResidualResidual DisposalDisposal OptionsOptions ¾¾ SolidSolid ResidualResidual DisposalDisposal OptionsOptions ¾¾ TransportingTransporting WasteWaste && WasteWaste BrokersBrokers ¾¾ AlternativesAlternatives 2 AcronymsAcronyms && AbbreviationsAbbreviations AA Activated Alumina BAT Best Available Technology CESQG Conditionally Exempt Small Quantity Generator CWA Clean Water Act DOT U.S. Department of Transportation ED/EDR Electrodialysis/Electrodialysis Reversal HMO Hydrous Manganese Oxide IX Ion Exchange LLRW Low Level Radioactive Waste LQG Large Quantity Generator NPDES National Pollutant Discharge Elimination System 3 AcronymsAcronyms && AbbreviationsAbbreviations PFLT Paint Filter Liquids Test POTW Publicly Owned Treatment Works RCRA Resource Conservation and Recovery Act SQG Small Quantity Generator SSCT Small System Compliance Technology TBLLs Technically Based Local Limits TCLP Toxicity Characteristic Leaching Procedure Technologically Enhanced Naturally Occurring TENORM Radioactive Material UIC Underground Injection Control USDW Underground Source of Drinking Water 4 DisposalDisposal OptionsOptions DependDepend OnOn…… ¾¾ WasteWaste characteristicscharacteristics z LiquidLiquid oror solidsolid z TypeType andand concentrationconcentration ofof contaminantscontaminants z ClassificationClassification ofof wastewaste • TENORM • Hazardous Waste • Source Material • Mixed Waste • Radioactive waste 5 DisposalDisposal OptionsOptions DependDepend OnOn…… ¾¾ Federal,Federal, state,state, && locallocal regulationsregulations ¾¾ DisposalDisposal facilityfacility policiespolicies ¾¾ SystemSystem && disposaldisposal sitesite locationlocation 6 LiquidLiquid ResidualsResiduals Acid Rinse BAT/SSCT Brine Backwash Neut. Concentrate Water Water IX X X X RO X AA X X X Coagulation/Filtration X Lime Softening X Green Sand Filtration X Co-Precip. w/ Barium X Sulfate ED/EDR X Pre-formed HMO X Filtration 7 SolidSolid ResidualsResiduals Spent Spent BAT/SSCT Resins/ Sludge Media Membranes IX X RO X AA X Coagulation/Filtration X X Lime Softening X X Green Sand Filtration X X Co-Precip. w/Barium Sulfate X X ED/EDR X Pre-formed HMO Filtration X X 8 DisposalDisposal OptionsOptions Possible Disposal Options Residuals Direct Discharge to Underground Landfill Discharge POTW Injection Liquids X X X Sludge X (X) X Spent X Resins/Media Spent X Membranes 9 LiquidLiquid Disposal:Disposal: DirectDirect DischargeDischarge ¾¾ MustMust havehave accessibleaccessible && appropriateappropriate receivingreceiving bodybody ¾¾ NPDESNPDES permitpermit limitationslimitations z NoNo federalfederal regulationsregulations inin placeplace forfor radionuclidesradionuclides 10 LiquidLiquid Disposal:Disposal: DischargeDischarge toto POTWPOTW ¾ MustMust meetmeet TBLLsTBLLs ¾ POTWPOTW cancan refuserefuse wastewaste ifif itit will:will: z Interfere with treatment process z Contaminate POTW sewage sludge z Cause NPDES permit violation ¾ MayMay needneed locallocal permitpermit oror contractcontract 11 LiquidLiquid Disposal:Disposal: DischargeDischarge toto POTW,POTW, cont.cont. ¾ DomesticDomestic sewagesewage exclusionexclusion ¾ RestrictionsRestrictions onon sourcesource materialmaterial ¾ StateState TENORMTENORM regulationsregulations maymay applyapply 12 LiquidLiquid Disposal:Disposal: UndergroundUnderground InjectionInjection ¾ UICUIC regulationsregulations definedefine ““radioactiveradioactive”” ¾ AdditionalAdditional statestate restrictionsrestrictions maymay applyapply ¾ ClassClass II wellswells z Possible option for radioactive & hazardous residuals z Stringent requirements z Limited disposal of sludge/solids 13 LiquidLiquid Disposal:Disposal: UndergroundUnderground Injection,Injection, cont.cont. ¾¾ ClassClass VV wellswells z ShallowShallow wellswells z MayMay notnot acceptaccept radioactiveradioactive wastewaste z NoNo hazardoushazardous wastewaste disposaldisposal 14 Liquid Residuals Disposal Consider intermediate No No Is there access to a Is there access to a Is underground injection No processing and/or waste receiving body? POTW? available? minimization methods or other disposal Yes options. Yes No Would the system’s Is the liquid considered discharge cause pass- Would injection to a Yes radioactive and/or Yes through or interference Class I well be the hazardous according to 10 at the POTW? Yes most cost-effective CFR Part 20, Appendix B, or practical (or only) Table II, Column 2 and 40 No option? CFR 261.3 respectively? Does the liquid meet Does the liquid No No direct discharge containing Ra or U meet requirements POTW discharge Yes (CWA/NPDES, state, requirements (CWA, and local limits)? state limits, TBLLs)? No Yes Contact the appropriate EPA regional or state Yes No Will the POTW accept UIC program office to the residual waste? see whether Class I injection (below a USDW) is a disposal Is direct discharge Yes Would injection to a option. the most cost- Class V well be the effective or practical Is discharge to a No most cost-effective (or only) option? POTW the most cost- No or practical (or effective or practical No only) option? (or only) option? Yes Yes Yes Secure a permit from Secure a permit from the state. the state. Contact the appropriate EPA regional or State UIC program office to see whether Class V injection (into or above a USDW) is a disposal option. Direct discharge. Discharge to POTW. 15 SolidSolid Residuals:Residuals: PrePre--testingtesting ¾¾ DetermineDetermine ifif wastewaste isis hazardoushazardous z ProcessProcess knowledgeknowledge and/orand/or z AnalyticalAnalytical testingtesting ¾¾ TCLPTCLP z PredictsPredicts leachingleaching ofof hazardoushazardous wastewaste z LevelsLevels setset forfor 88 metalsmetals && 3232 organicsorganics • Does not apply to radionuclides 16 SolidSolid Waste:Waste: PrePre--testing,testing, cont.cont. ¾¾ TestingTesting forfor freefree liquidsliquids z PaintPaint filterfilter liquidsliquids testtest z >> 20%20% solidssolids ¾¾ LandfillsLandfills dodo notnot acceptaccept wastewaste containingcontaining freefree liquidsliquids 17 SolidSolid Waste:Waste: PrePre--testing,testing, cont.cont. ¾ IntermediateIntermediate processingprocessing toto removeremove liquidsliquids ¾ NoNo federalfederal requirementrequirement toto testtest residualsresiduals forfor radionuclidesradionuclides 18 HazardousHazardous WasteWaste GeneratorsGenerators Status Generation Storage Conditionally Exempt Small < 100 kg < 1,000 kg Quantity Generator (CESQG) Small Quantity 100 – 1,000 kg 1,000 – 5,999 kg Generator (SQG) Large Quantity > 1,000 kg > 6,000 kg Generator (LQG) 19 SolidSolid Residuals:Residuals: MunicipalMunicipal && IndustrialIndustrial LandfillsLandfills ¾ RCRA - Subtitle D ¾ Municipal solid waste landfills z Non-hazardous TENORM z Hazardous waste from CESQGs ¾ Industrial solid waste landfills z Non-hazardous TENORM ¾ LandfillsLandfills maymay monitormonitor wastewaste 20 SolidSolid Residuals:Residuals: HazardousHazardous WasteWaste LandfillsLandfills ¾¾ RCRARCRA –– SubtitleSubtitle CC ¾¾ AllAll generatorgenerator classesclasses ¾¾ LandLand DisposalDisposal RestrictionsRestrictions (SQGs(SQGs && LQGs)LQGs) ¾¾ MayMay notnot acceptaccept TENORMTENORM ¾¾ PossiblePossible permitpermit conditionsconditions 21 SolidSolid ResidualsResiduals –– LLRWLLRW LandfillsLandfills ¾ BarnwellBarnwell -- SouthSouth CarolinaCarolina z Limited use after June 2008 ¾ RichlandRichland -- WashingtonWashington z Certain types of TENORM z Limited licensed source material disposal z No hazardous or mixed waste ¾ EnergySystemsEnergySystems –– Clive,Clive, UtahUtah z Dedicated TENORM disposal z Certain kinds of mixed waste 22 SolidSolid ResidualsResiduals –– MixedMixed WasteWaste FacilitiesFacilities ¾¾ EnergySystemsEnergySystems –– Clive,Clive, UtahUtah ¾¾ PermaPerma--FixFix EnvironmentalEnvironmental ServicesServices z EastEast TennesseeTennessee M&ECM&EC ¾¾ NSSINSSI 23 Solids Residual Disposal Use intermediate Identify the quality and Are there free liquids, Yes processing to separate quantity of the residual according to the PFLT? out the liquids No Sludge, Resin, Dispose of liquid Granular Media, AA residuals Dispose in a Media, Spent municipal landfill Membranes No Dispose in a municipal, industrial, hazardous Is the waste Does the waste waste, or LLRW landfill, or No Yes hazardous? contain radionuclides? any landfill licensed by the state to accept TENORM Yes waste Does the waste Dispose in a hazardous waste contain No landfill and meet all RCRA radionuclides? Subtitle C requirements Dispose in a landfill Yes licensed to accept mixed waste** Does the waste Yes contain non-exempt quantities of uranium Dispose in a LLRW landfill permitted to accept or beta/photon No hazardous waste or a hazardous waste landfill emitters?* licensed to accept TENORM waste 24 TransportingTransporting WasteWaste ¾¾ DOTDOT radioactivityradioactivity limitslimits maymay applyapply ¾¾ TransportingTransporting hazardoushazardous wastewaste z MayMay requirerequire EPAEPA IDID numbernumber z UniformUniform HazardousHazardous WasteWaste ManifestManifest ¾¾ CostsCosts cancan bebe significantsignificant 25 WasteWaste BrokersBrokers && TransportersTransporters ¾¾ PrivatePrivate firmsfirms thatthat maymay z RemoveRemove residualsresiduals fromfrom onon--sitesite z ProcessProcess residualsresiduals asas necessarynecessary z TransportTransport residualsresiduals toto disposaldisposal sitesite ¾¾ TreatmentTreatment vendorsvendors maymay offeroffer similarsimilar servicesservices 26 AlternativeAlternative OptionsOptions ¾ Incineration ¾ Evaporation ponds Intermediate processing methods ¾ Surface create additional impoundments residual streams ¾ Sludge dewatering Not encouraged unless there is a demonstrated ¾ Land application benefit, weighed against or soil mixing potential hazards & risks 27 Questions?Questions? 28.
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